Debate on Carried Interest

22 Pages Posted: 29 Oct 2018

See all articles by Calvin H. Johnson

Calvin H. Johnson

University of Texas at Austin - School of Law

Jeffrey H. Kahn

Harry W. Walborsky Professor, Florida State University College of Law; Associate Dean, Business Program

Douglas A. Kahn

University of Michigan Law School

Date Written: October 29, 2018

Abstract

In this point-counterpoint article, Johnson argues that the rationales offered by Professors Douglas and Jeffry Kahn do not justify giving fund managers capital gain treatment for carried interests. Johnson argues that the manager's return is entirely labor income, and that the manager has no capital or basis that causes their gains. Partnership taxation should not be available to hide partner-level compensation. The Kahns respond to thatcontention and defend their position.

Suggested Citation

Johnson, Calvin Harsha and Kahn, Jeffrey H. and Kahn, Douglas A., Debate on Carried Interest (October 29, 2018). 157 Tax Notes 1597, (Dec. 11, 2017); FSU College of Law, Public Law Research Paper No. 897; FSU College of Law, Law, Business & Economics Paper No. 18-14; U of Texas Law, Public Law Research Paper. Available at SSRN: https://ssrn.com/abstract=3274924

Calvin Harsha Johnson (Contact Author)

University of Texas at Austin - School of Law ( email )

727 East Dean Keeton Street
Austin, TX 78705
United States
512-232-1306 (Phone)
512-232-2399 (Fax)

Jeffrey H. Kahn

Harry W. Walborsky Professor, Florida State University College of Law; Associate Dean, Business Program ( email )

425 W. Jefferson Street
Tallahassee, FL 32306
United States
850.644.7474 (Phone)

HOME PAGE: http://www.law.fsu.edu/faculty/jkahn.html

Douglas A. Kahn

University of Michigan Law School ( email )

625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4043 (Phone)

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