Partner Sheldon Banoff will speak at the Chicago Bar Association's Federal Taxation Committee on "Partnership Carried Interests for Services - Where are We Now, and Where are We Going?" on Tuesday, February 26.
Service providers to partnerships and limited liability companies may receive a potentially valuable (vested or unvested) profits interest in the entity (a "carried interest") in exchange for their services. While proposed regulations dealing with the tax treatment of such carried interests are pending, tax legislation proposed in 2007 (which may be re-introduced) would substantially change the landscape further. Mr. Banoff's speech will discuss the current state of the law, recent legislative proposals, tax planning opportunities, and uncertainties (in 2008 and beyond) facing tax advisors and their clients who receive equity-flavored compensation for services.