Expertise in PE acquisitions, dispositions, and recapitalizations
New York
@alvarezmarsal
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Simon Bernstein is a Managing Director with the Global Transaction Tax group of Alvarez & Marsal Tax, LLC in New York. Mr. Bernstein’s primary areas of concentration are the tax aspects of mergers and acquisitions (M&A) with a focus on private equity acquisitions, dispositions, and recapitalizations, as well as in and out of court restructurings.
With more than 10 years of experience, Mr. Bernstein brings expertise in providing strategic counsel on domestic and international private equity and corporate tax matters, including tax due diligence, global tax structuring, cash tax modeling, capital structure planning, reorganizations, and integration of existing and acquired businesses.
Mr. Bernstein has advised clients across various industries, including financial services, healthcare, infrastructure, manufacturing, retail, software and technology, and wholesale distribution.
Mr. Bernstein has advised public and private “loss” companies (both pre- and post-bankruptcy) on the viability of their tax attributes, including the preparation of Section 382 analyses.
Mr. Bernstein earned a bachelor’s degree in finance (summa cum laude) from Yeshiva University and a J.D. (taxation concentration), from the Benjamin N. Cardozo School of Law. He is a member of the New York and New Jersey State Bars.
Many investors aware that a new tax applies to stock buybacks by public corporations (including the purchase of stock of a public corporation by its controlled affiliate) may not be aware of the full scope of the tax as enacted by Congress last year and interpreted by the IRS.
This paper discusses the limitation rules of section 382 of the Internal Revenue Code, of 1986, as amended (the “Code”), which limits the use of tax attributes after an ownership change.
As a result of the economic recession caused by the COVID-19 pandemic, many corporations find themselves with unprecedented losses from investments and operations.
A&M Taxand's detailed report on the section 382 rules that provide limitations on the use of tax attributes (carryforwards and built-in items) by corporations. The report also discusses the related rules under section 384 and the separate return limitation year (SRLY) limitation rules that apply to consolidated subsidiaries.
Latest insightsThe latest insights from Simon Bernstein's team
Multinational companies operating in Brazil must evaluate their current transfer pricing models to determine how they will adapt to the new transfer pricing system proposed by the Brazilian tax authority.
