In the preamble to the proposed regulations, the IRS highlights transactions in which one party provides services and another party receives a “seemingly associated” allocation and distribution of partnership income or gain - for example, a management company provides services to a fund in exchange for a fee that it may waive, and a party (usually the general partner entity) related to the management company receives an interest in future partnership profits the value of which approximates the amount of the waived fee. However, that tax treatment does not apply if: (i) the profits interest relates to a substantially certain and predictable stream of income from partnership assets (ii) the partner disposes of the profits interest within two years of receipt or (iii) the profits interest is a limited partnership interest in a publicly traded partnership. In Revenue Procedure 93-27, the IRS takes the position that the receipt of a partnership profits interest for services is not a taxable eventso long as the person receives that interest either as a partner or in anticipation of becoming one. That allows the general partner and/or management company to potentially take advantage of a deferral of income and the preferential capital gains tax rate. In lieu of that fee, the general partner receives an increased share of profits to qualify as a “profits interest” under an existing IRS revenue procedure, Revenue Procedure 93-27. So, what are management fee waivers and why has the IRS shown such concern? Typically, a management fee waiver is part of a fund structure whereby the general partner of a private equity or hedge fund, or a related management company, “waives” the management fee (say 2% of assets or committed capital per annum), typically paid quarterly and taxed as ordinary income for federal income tax purposes. The proposed regulations would be effective on the date final regulations are published in the Federal Register and would apply to any arrangement entered into or modified on or after the date of publication. On July 22, 2015, the IRS issued proposed regulations which, if finalized in substantially their current form (together with a revenue procedure to be released in conjunction with final regulations, discussed below), could force private equity and hedge funds to re-evaluate how they are structured for carry and fee waiver purposes. Financial Services Groupįor a number of years, the IRS has indicated that it was examining so-called “management fee waiver” strategies.
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