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U.S. Treasury › Profits Interests

Kramer Levin Naftalis & Frankel LLP

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

Kramer Levin Naftalis & Frankel LLP on

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

White and Williams LLP

Taxation of Carried Interests: 2017 Tax Act and Supplemental Guidance

White and Williams LLP on

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

Jackson Walker

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

Jackson Walker on

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

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

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

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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