Gary Michel

Gary Michel

Ervin Cohen & Jessup LLP

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Converting a Profits (or Carried) Interest Into a Capital Interest Tax-Free, Even if it is a Marketable Security

In CCA 201517006 (dated 10/9/14 and released 4/24/15), the general partner of a publicly traded partnership (PTP) had, in addition to its capital interest, a profits interest in the PTP called “incentive distribution rights”...more

7/16/2015  /  Corporate Taxes , General Partnerships , IRS , Limited Partnerships , Partnership Interests , Profits Interests , Publicly-Traded Companies , Right of Distribution , Securities
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