Tax Talks

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Malcolm Hochenberg

Malcolm Hochenberg

Senior Counsel

Malcolm S. Hochenberg is a senior counsel in the Tax Department. Malcolm has a broad practice, including inbound and outbound mergers and acquisitions, capital markets transactions, financial products, cross-border investments (with some emphasis on joint ventures involving intellectual property and other businesses) and tax controversies. Malcolm represents public companies, closely-held companies, asset managers and high-net-worth individuals.

In 2013, Malcolm was the chairperson of “Under 10,” which is the New York State Bar Association Tax Section’s group for lawyers with ten years or less of practice experience. In 2014, Malcolm co-authored a report to the IRS and Treasury Department on certain “partnership built-in loss” regulations prepared under the auspices of the NYSBA Tax Section.

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Summary of the Opportunity Zone Program

The Tax Cuts and Jobs Act enacted section 1400Z-2 of the Internal Revenue Code, which created the qualified opportunity zone program. The program is designed to encourage investment in distressed communities designated as “qualified opportunity zones” by providing tax incentives to invest in “qualified opportunity funds” (“opportunity funds”) that, in turn, invest directly or indirectly … Continue Reading

Impact of Recent Tax Legislation on M&A Transactions

This post outlines at a high-level certain provisions under the recently enacted 2017 tax legislation (Pub. L. 115-97, the “Tax Act”) that may affect M&A Transactions.  Some of these rules are very complex, particularly in cross-border transactions, and this post describes them in general terms without all of their fine details.  The discussion of foreign … Continue Reading
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