IRS Issues Proposed Guidance on "Disguised Payments For Services" Addressing Management Fee Waivers

    View Authors July 2015

    A long-awaited notice of proposed rulemaking provides guidance for determining whether an arrangement will be treated as a “disguised payment for services” as opposed to an allocation of a distributive share of income for federal tax purposes. The Notice has significant implications for management fee waivers and for carried interests provided to recipients that do not provide services to the partnership.