Showing 4 posts by Benjamin W. Hager.
2019 Update – How to Deal with Section 1061's Three Year Holding Period Requirement for Carried Interests
Hedge fund, private equity and real estate professionals value the carried interest because it allows them to be compensated for their services at long-term capital gains rates. In a prior article, we discussed the impact of the new IRC § 1061 and provided a summary of its rules. This article provides an update on the status of IRC § 1061 and discusses methods for avoiding its application. Read More ›
IRC § 1202 has been around for years, but has not received a lot of attention. This inattention has resulted in large part from IRC § 1202's complicated qualification rules, not to mention the planning uncertainties associated with a required five-year holding period. Read More ›
Investment fund managers value compensation in the form of carried interests, which allows them to be compensated for services with income that qualifies for long-term capital gains tax treatment. Numerous efforts have been made during the past decade to cut back or eliminate the favorable tax treatment of carried interests. Read More ›
Partnership and LLC Alert: Some Workers Treated as Employees for Tax Purposes May Need to be Reclassified as Partners as Early as August 1, 2016
On May 4, 2016, the federal government issued new temporary and proposed regulations that address employment taxes with respect to certain workers who both own equity interests in a partnership or LLC (taxed as a partnership and referred to as a “tax partnership”) and are employed by an LLC that is wholly-owned (a “disregarded entity” for tax purposes) by that tax partnership. Read More ›
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Scott W. Dolson is a member of FBT, providing corporate, tax and M&A services to LLCs, corporations and partnerships. This includes tax planning for the formation of closely held businesses, LLCs and FLPs and the structuring of syndicated private offerings.