Holme Roberts & Owen LLP

Holme Roberts & Owen LLP (HRO) has a tradition of building lasting relationships with entrepreneurial pioneers, from railroads and mining, to oil and gas, and more recently technology and telecommunications. For more than 100 years, HRO has provided clients with the resources and capabilities to address their legal concerns. Approximately 250 lawyers at HRO serve clients in the United States and abroad from eight offices in Denver, Boulder, Colorado Springs, Colorado; Salt Lake City, Utah; San Francisco, Los Angeles, California; London and Munich. Whether a client is an individual or part of a corporation, partnership or other business entity, HRO can provide legal counsel to fit the client's needs. Nearly half of HRO's lawyers represent clients in lawsuits, administrative proceedings and other means of resolving disputes. Notably, HRO is internationally-recognized for its corporate and litigation practices and is the only Denver-based firm with an international office in London. Lawyers from the corporate, securities, emerging growth, tax, banking, finance, bankruptcy and real estate practice groups assist large and small entities in both routine and extraordinary aspects of their businesses. Because business today is transacted in a global marketplace, HRO lawyers also advise United States-based and foreign companies on business transactions domestically and abroad.

IRS Provides Transition Relief for "Tainted" Performance-Based Compensation
Christine McCue Daly, March 14, 2008
On February 21, 2008, the Internal Revenue Service (IRS) released additional guidance confirming, expanding, and providing transition relief for its recent change in position regarding the deductibility of performance-based compensation under Section 162(m) of the Internal Revenue Code where the...

Tax Shelter Penalties and the Hippocratic Oath
Michelle Ferreira, March 14, 2008
The Internal Revenue Service (IRS) recently announced that tax fraud in the medical and healthcare professions continued to be an area of emphasis by the Service, particularly as it involves doctors, dentists, and chiropractors who have participated in "abusive tax avoidance...

Action Plan for "Tainted" Performance-Based Compensation
Christine McCue Daly, March 13, 2008
On January 25, 2008, the IRS released to the public a private letter ruling, PLR 200804004, which reversed its prior position and held that compensation paid to an executive upon attainment of a performance goal will not be considered performance-based compensation for purposes of Section 162(m),...