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Internal Revenue Code (IRC) Profits Interests

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

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

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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