Richard Zarin

Dec 4, 2023 | morganlewis.com | Jennifer Breen |Richard Zarin |Daniel Carmody |Stephen C. Tirrell

Private equity, hedge fund, and other investment fund sponsors should be aware of the recent development in the Internal Revenue Service’s (IRS’s) audit campaign with respect to potential liability for Self-Employment Contributions Act (SECA) tax on investment professionals through their limited partnership interests in fund management vehicles.

May 25, 2023 | lexology.com | Sarah-Jane Morin |Richard Zarin |Daniel Carmody |Daniel Nelson |Scott Lee |Kendall J. Keshtkar

A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a partnership profits interest in exchange for services can support non-taxable treatment at grant. WHAT IS A PROFITS INTEREST? Under IRS Revenue Procedure 93-27 [1] (Rev.

May 25, 2023 | morganlewis.com | Sarah-Jane Morin |Richard Zarin |Daniel Carmody |Daniel Nelson

A recent US Tax Court case upholds profits interest treatment for a taxpayer’s receipt of a partnership interest granted in exchange for services. The case highlights how properly structuring and documenting the grant of a partnership profits interest in exchange for services can support non-taxable treatment at grant. WHAT IS A PROFITS INTEREST? Under IRS Revenue Procedure 93-27 [1] (Rev.