Chair: Heesun Grace Kim, Grant Thornton LLP, Washington, DC
This panel will discuss recent developments in the area of partnership taxation, including legislation, regulations, administrative guidance and noteworthy cases.
Moderator: Tom West, KPMG LLP, Washington, DC
Panelists: Bryan Rimmke, Attorney-Advisor, Office of Tax Policy, Department of Treasury, Washington, DC (Invited)
How Far Will You Carry Your Client?
Section 1061 As It Stands Today. This panel will discuss section 1061 (the so-called “carried interest” provision) enacted under the TJCA. The panel will outline the technical aspects of section 1061 and highlight some of its ambiguities. The panel will further discuss current developments that have occurred since its enactment—including specific guidance recommendations made by the Partnership Committee. The panel will also discuss what the future proposed regulations under section 1061 may provide.
Moderator: Todd Golub, EY, Chicago, IL
Panelists: Kara Altman, IRS Office of Chief Counsel (Passthroughs & Special Industries), Washington, DC (Invited); Audrey Ellis, PwC, Washington, DC; Morgan Klinzing, Pepper Hamilton LLP, Philadelphia, PA; Mike Scaramella, Deloitte LLP, Chicago, IL
Tax Issues of Dry Partnerships.
This panel will address tax issues that arise when a partnership owns stock in a corporation as its sole or primary asset, including section 704(b) allocation issues (e.g., with regard to preferred distribution rights), issuance of compensatory partnership interests to employees of the corporation, and the application of section 704(c).
Moderator: Eric Sloan, Gibson Dunn & Crutcher LLP, New York, NY
Panelists: Josh Brady, Grant Thornton LLP, Washington, DC; Erin Cleary, Debevoise & Plimpton LLP, New York, NY