News & Analysis as of

Profits Interests

DarrowEverett LLP

Private Equity Incentive Structures: What Management Needs to Know

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If a private equity buyer is exploring an acquisition of the company you manage, and you anticipate remaining involved in the business after the sale, there are a number of options that may be appealing to you. It is likely...more

Fox Rothschild LLP

The U.S. Supreme Court Unanimously Rules That Successful Trademark Plaintiffs Cannot Recover Profits From Named Defendants’...

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On February 26, 2025, the U.S. Supreme Court unanimously vacated a nearly $43 million award in a trademark dispute that raised the question of whether a defendant’s affiliates could be held liable for payment of a disgorged...more

McDermott Will & Emery

Key Takeaways | Family Offices: Evolution & Efficiencies

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This session of the Private Client West Coast Forum 2024 focused on recent developments, including income tax planning to support investment performance, executive compensation planning, private placement life insurance...more

Cozen O'Connor

IRS creates standardized Section 83(b) election Form 15620

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On November 7, 2024, the Internal Revenue Service (IRS) released Form 15620, Section 83(b) Election, which provides taxpayers a standardized form that they may choose to use when filing Section 83(b) Elections with the IRS....more

Opportune LLP

Exploring Profit Interests: Accounting & Valuation…

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Executives at both public and private companies commonly receive performance-based incentives. The objective is to link compensation closely to a firm's financial results. These performance-based incentives can take many...more

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

PilieroMazza PLLC

Unlocking the Potential of Phantom Equity: Incentive and Compensation Strategies to Attract and Retain Top Talent

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Navigating the landscape of employee incentives can be complex, particularly when exploring non-traditional compensation methods. Phantom stock, also known as synthetic equity, offers a unique solution for business owners...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

Skadden, Arps, Slate, Meagher & Flom LLP

Tax Court Holds Indirect Grant of Profits Interest To Be Non-Taxable, Citing IRS Guidance

On May 3, 2023, the U.S. Tax Court upheld a taxpayer’s reliance on Revenue Procedure 93-27 to characterize as a profits interest a partnership interest granted in exchange for services that were provided indirectly for the...more

Winstead PC

[Virtual Half-Day Seminar] Real Estate Startup - April 18th, 9:00 am - 12:15 pm CST

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On April 18, join Winstead attorneys Trip Dyer, Ben Gehlbach, Daniel Bell-Garcia, Jacob Loehr, Matt Dzura, and Cole Gearhart, along with Whitley Penn Partner Shea Krachek, for our Real Estate Startup half-day virtual seminar....more

Lippes Mathias LLP

How to Motivate Your Team with Equity Compensation: What Startup Companies Need to Know

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Cash-strapped startup companies often find themselves looking for creative ways to engage and retain qualified people. One common way is to offer different types of equity compensation. ...more

Holland & Hart - The Benefits Dial

B-Side – Dual Status Issues with Partnership LTI

Long term incentive plans offered by an entity that is taxed as a partnership present an additional problem compared to their corporate A-side counterparts. If an employee is given an equity interest in the partnership, the...more

Gray Reed

Were the Mineral Deeds a Gift or a Sale? It Made a Difference.

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The question presented in Aaron v. Fisher et al: Did mineral deeds bestow separate property upon the grantees by gift, or did they convey a community property interest to the grantees and their spouses by sale for...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

Kramer Levin Naftalis & Frankel LLP

Final Treasury Regulations Issued Addressing the Application of Section 1061 to Carried Interests

On Jan. 8, 2021, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued final regulations (Final Regulations) (T.D. 9945) governing the treatment of “carried interests” (also referred...more

Lowenstein Sandler LLP

COVID-19: Focus on Executive Compensation

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The impact of the COVID-19 pandemic on the business community is unprecedented. Every company and executive is questioning the effects the disease will have on their business, employees, customers, and local and global...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

Gray Reed

What is the Test For Good Faith in the Louisiana Civil Code?

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In Mary et al. QEP Energy Company  the question was, given an encroachment of a pipeline onto the property of another, what is the test for determining the good faith, or not, of the party in possession?...more

Bricker Graydon LLP

Ohio Supreme Court: Oil and gas royalty reservation preserved under the Ohio Marketable Title Act

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On December 13, 2018, in Blackstone v. Moore, 2018-Ohio-4959, the Ohio Supreme Court ruled that a reference that includes the type of interest created and to whom the interest was granted is sufficiently specific to preserve...more

Opportune LLP

Profits Interests: Accounting & Valuation Considerations

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Executives at both public and private oil and gas companies commonly receive performance-based incentives. The objective is to link compensation closely to the financial results of a firm. These performance-based incentives...more

Gray Reed

Attempt to Prove a Texas Partnership Fails

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Like breaking into CIA headquarters, sneaking into the Vatican, or hanging off the side of the Burj Khalifa, sometimes getting the deal done seems impossible. The key to any successful mission is planning for disastrous...more

Farrell Fritz, P.C.

Universal Obtains More Than It Bargained For in Deals with Cash Money Records: Potential Liability for Unpaid Drake Profits

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For those unfamiliar with what today’s young kids are listening to, Aubrey “Drake” Graham is one of the most commercially-successful recording artists of all time, with multiple multiple-platinum records to his credit. For...more

White and Williams LLP

Taxation of Carried Interests: 2017 Tax Act and Supplemental Guidance

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The ability of a partnership to grant service providers (typically key management) an interest in a partnership on a non-taxable basis, with potential long-term capital gain treatment on post-grant appreciation, is unique to...more

Bradley Arant Boult Cummings LLP

Investor, Beware: New Prosecutorial Scrutiny of Private Equity Investment in Healthcare Companies

A bedrock principle of private equity investment is that investors expect to make money on their investments. A recent lawsuit by the Department of Justice (DOJ), however, might force private equity investors in healthcare to...more

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