Section 280E of the Internal Revenue Code provides that no deduction or credit shall be allowed for any amount paid or incurred in carrying on any trade or business if such trade or business consists of trafficking in...more
Due to COVID-19 closures at the Internal Revenue Service (IRS), EIN applications that are submitted by telephone, fax or mail currently are not being received or processed. Accordingly, non-U.S. applicants (who generally are...more
On July 22, 2015, the IRS released proposed regulations that could limit the utility of “management fee waiver” arrangements (the “Proposed Regulations”). Management fees generally are taxable as compensation income....more
7/31/2015
/ Capital Gains ,
Clawbacks ,
Deferred Compensation ,
Fee Waivers ,
Fund Sponsors ,
Internal Revenue Code (IRC) ,
IRS ,
Management Fees ,
Partnership Agreements ,
Partnerships ,
Profits Interests ,
Significant Entrepreneurial Risk (SER)