News & Analysis as of

Waivers Management Fees

Eversheds Sutherland (US) LLP

IRS Begins to Target Management Fee Waivers on Audit

According to a recent BNA news report, the Internal Revenue Service (IRS) has proposed adjustments and penalties to a private fund manager related to its use of management fee waivers and transaction fee offsets. Based on the...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

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

Pillsbury Winthrop Shaw Pittman LLP

Proposed Regulations Target Management Fee Waivers

In the Federal Register for July 23, 2015, the Treasury Department published proposed regulations regarding the circumstances under which partnership allocations and distributions will be treated as disguised payments for...more

Goulston & Storrs PC

IRS Slams Profits Interests In Lieu of Management Fees and More

Goulston & Storrs PC on

The IRS issued the much anticipated proposed regulations that severely curtail the practice of a fund manager waiving management fees in exchange for a share of future partnership profits. In essence the regulations tighten...more

Latham & Watkins LLP

IRS Issues Proposed Regulations Addressing Management Fee Waivers

Latham & Watkins LLP on

Certain arrangements would be recharacterized as ordinary income, rather than as distributive shares of partnership income. On July 22, 2015, the US Treasury Department and the US Internal Revenue Service (IRS) released...more

Locke Lord LLP

Private Equity and Hedge Fund Managers Take Caution - Proposed Treasury Regulations Threaten Management Fee Waivers

Locke Lord LLP on

On July 23, 2015, the Internal Revenue Service ("IRS") issued long-awaited proposed regulations discussing the taxation of management fee arrangements commonly used by private equity funds and their management. The proposed...more

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