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Partnership Agreements Internal Revenue Service Profits Interests

Whiteford

Client Alert: Update: How "Profits Interest" Works And Why Knowing That Can Matter A Whole Lot

Whiteford on

In many ways, the labor market is as competitive as ever. Businesses continue to explore compensation packages, in addition to ordinary salary, that will help them attract, hire and retain talent. One method of compensation...more

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS Proposes Regulations Addressing Profits Interests, Investment Fund Fee Waiver Arrangements"

On July 23, 2015, the Internal Revenue Service (IRS) and the Treasury Department proposed regulations that address the tax treatment of certain partnership interests issued in exchange for services. Of particular note, the...more

Foley Hoag LLP

Changes on the Horizon? IRS Announces New Plans to Recharacterize Management Fee Waiver Arrangements

Foley Hoag LLP on

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

Bracewell LLP

Proposed IRS Regulations Target Management Fee Waiver Arrangements

Bracewell LLP on

On July 22, 2015, the Treasury Department and the Internal Revenue Service (“IRS”) released proposed regulations (the “Proposed Regulations”) regarding disguised payments for services under Section 707(a)(2)(A) of the...more

Goodwin

New Proposed Treasury Regulations Focus on Management Fee Waivers

Goodwin on

On July 22, 2015, the U.S. Treasury Department and Internal Revenue Service released proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code relating to disguised payments for services between partners...more

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