In the early 1990s, Congress enacted the qualified small business stock (“QSBS”) rules to incentivize equity investments in certain corporations. The QSBS rules reduce the effective federal income tax rate on the gain...more
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
7/31/2015
/ Capital Gains ,
Clawbacks ,
Deferred Compensation ,
Fee Waivers ,
Fund Sponsors ,
Internal Revenue Code (IRC) ,
IRS ,
Management Fees ,
Partnership Agreements ,
Partnerships ,
Profits Interests ,
Significant Entrepreneurial Risk (SER)
On January 2, 2013, President Obama signed into law the American Taxpayer Relief Act of 2012 (the “Act”).
Among its provisions, the Act extends a tax benefit whereby capital gains from the sale or exchange of certain...more