Tax Analysts Announces Monthly Column on Partnerships
Appears in This Week’s Tax Notes Magazine, Tax Notes Today
(Logo: http://www.newscom.com/cgi-bin/prnh/20060914/TALOGO )
The column, by PricewaterhouseCoopers LLP tax professionals
Jackel, a managing director at PricewaterhouseCoopers Washington National Tax Services (WNTS) in
Crnkovich, a principal with PricewaterhouseCoopers Washington National Tax Services in
The new column will address current topics of interest in partnership taxation and provide perspectives on the current state of the law, recent developments in IRS guidance and case law, recent legislative developments, and perspectives on where Congress should change the law to address issues and problems of interest to practitioners and the government.
Today’s column examines timing and character issues regarding certain deferred compensation arrangements. Specifically, it focuses on the timing issues surrounding partnership allocations as deferred compensation under sections 409A and 457A, and character issues surrounding partnership allocations under recently proposed legislation in the area of carried interest.
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