Quote:
Originally posted by taxwonk
The carried interest is compensation. Just like the stock options and restricted stockgrants corporatee drones get. Just like the commissions the stockbrokers and other peddlers get. Just like the management fee. It's income. It's not capital gain for the PEs. They never put capital in. That's why it's called a "carried" interest.
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Wait. You meant there's no difference between having a flow through interest in a partnership and having an equity interest in a corporation?
And last time I checked, my guys took their restricted stock into income based on its current value and all the gain was... well... gain.
Also, are you suggesting that when they have both a carried interest and an investment interest (because in my deals they always do), that they have two separate interests in the partnership, not a single unified interest?
So on the issue of the aggregate versus entity approaches to partnerships, are you going to advocate a consistent entity approach - just like corporations?