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Partnerships › Fee Waivers

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

Dechert LLP on

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"

Skadden, Arps, Slate, Meagher & Flom LLP on

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

Cooley LLP

Alert: IRS Issues Long-Awaited Proposed Regulations on Management Fee Waivers

Cooley LLP on

On July 22, 2015, the Treasury Department and the IRS published proposed regulations (the "Proposed Regulations") that address the circumstances in which allocations or distributions made by a partnership to a partner that...more

Seyfarth Shaw LLP

Proposed Treasury Regulations Offer Guidance on Disguised Payments for Services

Seyfarth Shaw LLP on

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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