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Proposed Rules on Partner Net Worth, Bottom Guarantees and Other Issues 2014

 
Author(s): Jennifer H. Alexander, Clifford M. Warren
Practice Area: Tax
Published: May 2014
PLI Item #: 56191
CHB Spine #: D413

Jennifer H. Alexander rejoined the Passthroughs group in the National Tax Office of Deloitte Tax LLP as Co-Managing Principal, where she specializes in the use of partnerships and limited liability companies in domestic and cross-border mergers and acquisitions, financing transactions, and restructurings.

Prior to returning to Deloitte, Jennifer served in the Office of Tax Legislative Counsel at the U.S. Department of the Treasury as an Attorney Advisor.

Jennifer has authored articles that have appeared in numerous professional publications, including Tax Notes, Journal of Taxation, TAXES, and Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures, & Other Strategic Alliances (Practising Law Institute).  Jennifer is a frequent lecturer on a variety of topics dealing with U.S. federal income taxation, having spoken at many of the country’s leading tax conferences, including the Practising Law Institute, the Southern Federal Tax Institute, the New York University’s Institute on Federal Taxation and Summer Institute on Federal Taxation, the American Bar Association Tax Section, and the Tax Executives Institute.

Jennifer received her B.A. in Government and Politics from the University of Maryland, and her J.D. from the Georgetown University Law Center.  Jennifer is a member of the American Bar Tax Section, a member of the Tax Section’s Committee on Partnerships and LLCs, and former CLE Chair for the committee.  In 2006, she was the recipient of the American Bar Association Tax Section’s John Nolan Fellowship.  She is a member of the State Bar of Maryland and is admitted to practice in Maryland.


Cliff Warren is a graduate of Middlebury College (BA), New York Law School (JD) and New York University School of Law (LLM Tax). 

Cliff started out with the law firm of Breed Abbott & Morgan.  He worked on investment matters at The Equitable, was head of tax at GE Capital Corporate Financial Services, DB Zwirn & Co. (a NYC hedge fund) and Kohlberg Kravis Roberts & Co (a NYC private equity firm).  Cliff is currently with the Chief Counsel’s Office at the IRS serving as Special Counsel in the Passthroughs and Special Industries Division.