Taxation of Carried Interests for Senior Level Fund Managers

Hedge Fund Law Journal (March 7/14/21/28, 2019) (reprinted in Private Equity Law Report (commencing August 6, 2019))

18 Pages Posted: 8 Apr 2019 Last revised: 7 Aug 2019

See all articles by Arthur H Kohn

Arthur H Kohn

Cleary Gottlieb Steen & Hamilton LLP

Andrew L. Oringer

The Wagner Law Group; Fordham Law School; Hofstra University - Maurice A. Deane School of Law

Steven Rabitz

Dechert LLP

Date Written: March 28, 2019

Abstract

This article summarizes the principal U.S. federal income tax and related design considerations associated with carried interest arrangements for individuals who are employed by or otherwise provide services to sponsors of private investment funds. The article is intended to provide background to those interested in the design of carried interest arrangements and to serve as a useful practical checklist of relevant tax considerations.

Suggested Citation

Kohn, Arthur H and Oringer, Andrew L. and Rabitz, Steven, Taxation of Carried Interests for Senior Level Fund Managers (March 28, 2019). Hedge Fund Law Journal (March 7/14/21/28, 2019) (reprinted in Private Equity Law Report (commencing August 6, 2019)), Available at SSRN: https://ssrn.com/abstract=3317099

Arthur H Kohn

Cleary Gottlieb Steen & Hamilton LLP

One Liberty Plaza
New York, NY 10006
United States

Andrew L. Oringer (Contact Author)

The Wagner Law Group

747 Third Avenue
16th Floor
New York, NY 10017-2856
United States
1-212-540-4579 (Phone)

Fordham Law School ( email )

150 West 62 Street
New York, NY 10023
United States

Hofstra University - Maurice A. Deane School of Law ( email )

121 Hofstra University
Hempstead, NY 11549
United States

Steven Rabitz

Dechert LLP ( email )

1095 Avenue of the Americas
New York, NY 10036
United States

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