With this column, we continue a review of the legislation which has passed the House of Representatives, referred to here as the 2009 Levin Bill,1 to tax carried interests as ordinary income. The April 2010 column discussed the current taxation of carried interests which is proposed to be changed by the 2009 Levin Bill.2
The bill3 contains three parts: (1) The first part amends Section 83 dealing with the transfer of partnership interests in exchange for the performance of services; (2) The second part deals with the treatment of investment services partnership interests (ISPIs); and (3) The third part addresses certain tax sharing agreements.
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