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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
ISBN: 9781402422270
PLI Item #: 56191
CHB Spine #: D413

Jennifer H. Alexander is the Co-Managing Principal of the Passthroughs group in the National Tax Office of Deloitte Tax LLP, 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 is the co-author of the WG&L treatise on Partnership taxation.  In addition, she 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 and Vice Chair of the Tax Section’s Committee on Partnerships and LLCs.  She is a member of the State Bar of Maryland and is admitted to practice in Maryland.

Cliff Warren is Senior Counsel in the Passthroughs Group in the Office of Chief Counsel.  Prior to this, Cliff was head of tax at KKR and, before that, a large NYC hedge fund.  Cliff was also Tax Director of GE Capital Commercial Finance for about ten years.  He is a graduate of Middlebury College, New York Law School and the NYU tax program.