|
Tuesday, September 04, 2007
JCT on Carried Interest
Although it hasn't provided a scoring of the proposal by Rep. Sander Levin (D-MI) to close the carried interest tax loophole, the Joint Committee on Taxation released two documents yesterday on various aspects of the current tax treatment of carried interests.
Present Law And Analysis Relating to Tax Treatment of Partnership Carried Interests and Related Issues, Part I provides:
- background information about carried interests and going-public transactions of partnerships involved in private equity, hedge fund, venture capital fund, and similar alternative asset management and financial advisory business activities
- economic data relating to partnerships, and to private equity, venture capital, and hedge funds, and certain carried interests
- a description of present law relating to Federal tax rates for individuals, tax treatment of partnership profits interests for services, and tax rules relating to compensation and employment tax
- a description of present law relating to taxation of partners and partnerships, including publicly traded partnerships, and compares the tax treatment of taxable corporations and of passthrough and untaxed entities
- a description of recent legislative proposals
Present Law And Analysis Relating to Tax Treatment of Partnership Carried Interests and Related Issues, Part II provides:
- background information about offshore structures for private equity, hedge fund, venture capital fund, and similar alternative asset management and financial advisory business activities
- background information about tax-exempt investors and unrelated business income tax, foreign individual investors and income effectively connected to a trade or business, and deferral of income of managers
- a geographic distribution of hedge funds and private equity funds
Posted by Dana Chasin
|