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Private Equity Profits Interests

DarrowEverett LLP

Private Equity Incentive Structures: What Management Needs to Know

DarrowEverett LLP on

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

Opportune LLP

Exploring Profit Interests: Accounting & Valuation…

Opportune LLP on

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

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

Herbert Smith Freehills Kramer

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

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

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