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Originally posted by Greedy,Greedy,Greedy
Wait. You meant there's no difference between having a flow through interest in a partnership and having an equity interest in a corporation?
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No.
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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.
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What your guys are doing is recognizing income based upon the diffference between what they pay for the stock and its value at the time it vests, unless they were able to make a section 83(b) election to take it into income earlier.
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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?
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Yes. For one thing, they need to track their capital accounts separately. They also need to mainatina different interests to account for the flow of funds through the waterfall.
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So on the issue of the aggregate versus entity approaches to partnerships, are you going to advocate a consistent entity approach - just like corporations?
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When it comes to compensatory interests, fuck yeah.
etft -- t.s.