Patrick Hoehne

Managing Director
20 years of tax and audit experience, specializing in mergers and acquisitions
Background also includes tax due diligence, drafting opinion letters / ruling requests and preparing SEC tax disclosures and tax-related provisions in transaction documents
Serves corporate, private equity and individual clients in a wide range of industries
San Francisco
@alvarezmarsal
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Patrick Hoehne is a Managing Director with Alvarez & Marsal Tax in San Francisco.

Mr. Hoehne focuses on transactional and general corporate tax matters. He brings over 20 years of experience in private equity, corporate and individual tax and accounting matters, including mergers and acquisitions, tax planning and tax controversy matters.

His background also includes tax due diligence and structuring, drafting opinion letters/ruling requests and preparing tax-related provisions in transactional documents.

Mr. Hoehne has served corporate, private equity and individual clients in a wide range of industries, including technology, communications, entertainment, financial services, real estate investment trusts and public utilities.

Before joining A&M, Mr. Hoehne worked with the transactional group at FTI Consulting and the mergers and acquisitions tax group with Ernst & Young. He assisted in numerous transactions, dispositions and reorganizations of both public and private businesses. Notably, he performed extensive tax and financial due diligence on a wide range of companies and clients, including private equity firms, corporations, and partnerships.

Mr. Hoehne also worked at Wood & Porter, a tax law firm in San Francisco, representing individuals, partnerships and corporations in a variety of tax matters, and gained experience in the formation of entities, executive compensation, like-kind exchanges and the characterization of independent contractors for tax purposes. He regularly advised litigants about the tax treatment of damage awards.

Previously, he was a manager with the audit and business consulting practices of Arthur Andersen. As an auditor, he performed and reviewed audit procedures, drafted financial statements and reviewed financial transactions. As a consultant, he prepared expert witness reports related to tax, accounting and financial aspects of civil litigation, and financial due diligence for his corporate and private equity clients. He was awarded a fellowship in Arthur Andersen’s Office of Regulatory and Legislative Affairs in Washington, D.C.

Mr. Hoehne earned a J.D., with a specialization in business law and policy, from the UCLA School of Law. He also earned a bachelor’s degree in business administration, with a concentration in accounting, from California Polytechnic State University. He is admitted to practice law in California, where he also holds a CPA license.

NOTE: Alvarez & Marsal employs CPAs but is not a licensed CPA firm.

Insights By This Professional

When it comes to acquisitions and tax, there is nothing buyers love more than a good step-up. Check that — a great step-up. A step-up in the tax basis of the acquired assets allows the buyer to amortize the resulting identifiable intangibles and goodwill/going concern over a 15-year period.
At first glance, acquiring an S corporation is a seemingly innocuous event; after all, S corporations are “flow-through” entities that generally are not subject to income taxes. Instead, income, losses, deductions and credits all flow through to the shareholders and are reported on the shareholders’ respective federal income tax returns.
“Villainy, thy name is Taxpayer!” is what the IRS might wail if we all lived in a world encompassing a Shakespearean tragedy. Thankfully, we don’t.
It’s a tale as old as time itself: Buyer meets seller. Buyer falls in love with seller’s business. Buyer proposes to seller.
Latest insights The latest insights from Patrick Hoehne's team
Thought Leadership
During this engaging session, we explored key Dutch tax considerations and strategies to a successful tax integration after a deal.
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