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Internal Revenue Service › Management Fees › Internal Revenue Code (IRC)

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Morrison & Foerster LLP

Tax Court’s Decision in Soroban—Potential SECA Tax Implications for Management Fee Income

Morrison & Foerster LLP on

On May 28, 2025, the U.S. Tax Court issued its decision in Soroban Capital Partners LP v. Commissioner (T.C. Memo 2025-52) (“Soroban”), holding that “limited partners” of a management company organized as a Delaware limited...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

Morgan Lewis

IRS Issues Proposed Regulations Addressing “Fee Waiver” Arrangements

Morgan Lewis on

The proposed regulations may have a significant impact on certain “management fee waiver” arrangements that have become commonplace in the investment management industry....more

Proskauer Rose LLP

Proposed Regulations Issued On Management Fee Waivers

Proskauer Rose LLP on

On July 22, 2015, the U.S. Department of the Treasury and U.S. Internal Revenue Service issued proposed Treasury Regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended, addressing management...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

Troutman Pepper Locke

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

Troutman Pepper Locke 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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