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- Title
Management Fee Waivers: The Current State of Play.
- Authors
ASHRAF, SABA; PIRIO, ALYSON K.
- Abstract
Private equity fund management fee waivers are once again on the radar, on the heels of recent comments by IRS officials that the agency is contemplating issuing new guidance and the First Circuit's decision in Sun Capital . If effective, the waiver converts a fund manager's ordinary income for services into a future profits interest in the fund that yields income taxed at capital gains rates, so the industry has much at stake as this debate heats up. This article looks at recent developments in fee waiver arrangements and analyzes the arguments that the IRS is likely to consider.
- Subjects
UNITED States; PRIVATE equity funds; WAIVER; USER charges; UNITED States. Internal Revenue Service; SUN Capital Partners Inc.; UNITED States. Court of Appeals (1st Circuit); CAPITAL gains tax; ACTIONS &; defenses (Law); MANAGEMENT
- Publication
Journal of Taxation & Regulation of Financial Institutions, 2013, Vol 27, Issue 2, p5
- ISSN
1547-3996
- Publication type
Article