A Partner with the law firm of Kramer, Levin, Naftalis & Frankel LLP, Pamela Capps has more than 20 years’ experience providing legal and transactional advice in a wide variety of tax matters.
Ms. Capps’ practice includes structuring and providing ongoing advice to clients regarding mergers and acquisitions, transactions involving the formation, operations and dispositions of partnerships and limited liability companies, general tax matters, employee compensation, individual income tax issues and not-for-profit organizations. Ms. Capps has represented clients in numerous industries with extensive experience in media/entertainment, real estate and licensing matters. She also represents clients in federal and state tax controversies.
Ms. Capps is recognized as a leading lawyer by Legal 500 (2014 - 2017), New York Super Lawyers (2009-2017), and Super Lawyers’ Top Women (2014-2017).
J.D., Columbia Law School (1992)
B.S.B.A., Washington University (1987) with high honors
Bloomberg Tax Management Portfolios
The Portfolio, Transfers to Controlled Corporations: Related Problems, discusses the relationship between §351 and other provisions of the Code.
The Portfolio, Transfers to Controlled Corporations: In General, No. 758, discusses the tax considerations of transferring property to corporations controlled by the transferors.
Capital Assets discusses in detail the provisions of §1221, summarizing its historical development, analyzing its definitions, and describing doctrines and other statutory provisions.
This Bloomberg Tax Portfolio focuses its discussion on the “sale or exchange” requirement that is necessary in order for a capital asset to qualify for capital asset treatment under §1221; the interpretation