| 来源类型 | Article
|
| 规范类型 | 评论
|
| The Taxation of Carried Interests in Private Equity |
| David A. Weisbach
|
| 发表日期 | 2008-05-01
|
| 出版年 | 2008
|
| 语种 | 英语
|
| 摘要 | This essay analyzes the tax treatment of carried interests in private equity. It argues that there are two competing analogies: service income and investment income. Standard approaches are not able to resolve which of the competing analogies is better and often fail even to recognize that there are competing analogies. The best method for determining the proper treatment of carried interests is through direct examination of the effects of each of the possible treatments, known as the theory of line drawing in the tax law. Using this approach, it is clear that the better treatment of holders of carried interests is as investors. Key pieces of evidence include the longstanding policy premises behind partnership taxation and the complexity and avoidance problems with attempts to tax carried interests as service income. In particular, the longstanding policy behind partnership taxation is to tax partners as if they engaged in partnership activity directly. Current law, which gives holders of carried interests capital gains treatment follows this approach, and changing the law to tax carried interests as service income would require rejection of this historical trend. Because such an approach would mean taxing carried interests differently than if the partners engaged in the activity directly, it would be easily avoidable. Moreover, attempts to tax carried interests as service income will have to be able to distinguish service income from other types of income, a task which has proven to be difficult and complex. . . .
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David Weisbach is a visiting scholar at AEI. |
| 主题 | Economics
; Public Economics
|
| 标签 | carried interest
; income
; investment
|
| URL | https://www.aei.org/articles/the-taxation-of-carried-interests-in-private-equity/
|
| 来源智库 | American Enterprise Institute (United States)
|
| 资源类型 | 智库出版物
|
| 条目标识符 | http://119.78.100.153/handle/2XGU8XDN/245621
|
推荐引用方式
GB/T 7714 |
David A. Weisbach. The Taxation of Carried Interests in Private Equity. 2008.
|
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