fee waiver Tag

In July 2015, the U.S. Department of the Treasury issued proposed regulations (REG-115452-14) pursuant to IRC 707(a)(2) addressing the tax treatment of certain private equity management fee waivers. Under the proposed regulations, the conversion of a management fee to a capital contribution without any “significant...

Service partnerships and fund managers best beware: The IRS has issued proposed regulations under §707(a)(2) to determine when distributions to a partner are in fact disguised payments for services. These proposed regulations target various disguised payments for services, but especially attack management fee waivers. In...

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