transcript   Transcript

Compensatory Interests and Other Arrangements Including Options and Phantom Equity

Recorded on: Jun. 7, 2018
Running Time: 00:59:05

Full Transcript:



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Taken from the Web Program Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances Recorded June, 2018 in San Francisco [00:59:05]

Use of partnership equity for compensation, such as profit interests and capital interests, options, warrants, and equity appreciation rights, restricted versus unrestricted; the extent to which Section 83 applies, proposed regulations dealing with service partners, and possible “carried interest” legislation, management fee waivers Sections 409A and 457A and the impact of tax reform
Julie A. Divola, Samuel T. Greenberg, Clifford M. Warren [Senior Counsel to the Associate Chief Counsel (Passthroughs & Special Industries), Internal Revenue Service]

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Presentation Material
  • Compensatory Interests and Other Arrangements
    Julie A. Divola, Samuel T. Greenberg
    • (s)
      Julie A Divola ~ Pillsbury Winthrop Shaw Pittman LLP
      Samuel T Greenberg ~ Munger, Tolles & Olson LLP
      Clifford M Warren ~ Senior Level Counsel to the Associate Chief Counsel (Passthroughs & Special Industries), Internal Revenue Service
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