July 28, 2015
Basket Case? IRS Designates Basket Options as Listed Transactions
Having previously expressed its disapproval of Basket Option Contracts (CCA 201426025), IRS upped the ante in Notice 2015–47 and Notice 2015–48 by designating such options as listed transactions and transactions of interest, respectively. These ...
July 29, 2015
Management Fee Waiver - Partnership Profits Interest or Disguised Compensation for Services
On July 22, 2015, the Treasury Department released Proposed Regulations under Internal Revenue Code Sec. 707, Transactions Between Partner and Partnership, addressing the taxation of management fee waivers (MFW).
In a typical MFW, a private equity ...
