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Partnerships Profits Interests Internal Revenue Service

Whiteford

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

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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

Rivkin Radler LLP

Indirectly Held Profits Interests and Rev. Proc. 93-27

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At war with Russia in eastern Europe, a nascent competing world order, mass shootings and bank failures at home, questionable audit practices by the Big 4 . . . everywhere, debt ceilings and the risk of default, inflation,...more

Rivkin Radler LLP

Biden’s 2022 Revenue Proposal, Profits Interests, And The Alchemy Of Compensation

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Recap- Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held...more

Neal, Gerber & Eisenberg LLP

NGE On Demand: Profits Interests: Granting & Receiving with Patty Cain and Josh Klein

Interested in granting or receiving profits interests but confused by its features? NGE attorneys Patricia Cain and Josh Klein walk you through the compensation, tax, and corporate elements to consider as you navigate this...more

Hutchison PLLC

What is a Profits Interest?

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Equity compensation can be different in LLCs and corporations. LLCs have the benefit of using a special equity compensation tool called a “profits interest.” Unlike a traditional stock option, which represents a right to...more

Jackson Walker

Proposed Treasury Regulations Address Private Equity Management Fee Waivers and Profits Interests

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The Internal Revenue Service ("IRS") and Treasury Department recently released proposed regulations under section 707(a)(2)(A) of the Internal Revenue Code of 1986 (the "Code) addressing the issuance of certain interests in...more

McDermott Will & Emery

Proposed Regulations Require Significant Entrepreneurial Risk for a Service Partner's Income to be a Distributive Share

McDermott Will & Emery on

On July 22, 2015, the U.S. Department of the Treasury and the Internal Revenue Service (IRS) released proposed regulations under Section 707(a)(2)(A) (the proposed regulations) which would treat certain partnership...more

Dechert LLP

A Sea Change for Waive-rs? - Proposed Regulations Address Tax Treatment of Management Fee Waivers

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The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) have issued proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the “Code”), covering the...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

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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

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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

Seyfarth Shaw LLP

Proposed Treasury Regulations Offer Guidance on Disguised Payments for Services

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Fee waivers by partners for services rendered to their partnerships will now be subject to scrutiny by the Internal Revenue Service (the “IRS”), pursuant to the Treasury Department’s notice of proposed rulemaking (the...more

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