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Analyzing The Noncompensatory Partnership Option Proposed Regulations, Dennis A. Diersen
Analyzing The Noncompensatory Partnership Option Proposed Regulations, Dennis A. Diersen
William & Mary Annual Tax Conference
No abstract provided.
Options To Acquire Partnership Interests: Can The Tax Law Keep Pace?, Walter D. Schwidetzky
Options To Acquire Partnership Interests: Can The Tax Law Keep Pace?, Walter D. Schwidetzky
All Faculty Scholarship
It has become increasingly common for partnerships to issue options that give the holder the right to acquire an interest in the partnership for a set price. The holder of the option will exercise it if he feels that the partnership interest to be acquired is worth more than the exercise price. There is a dearth of authority on the federal tax treatment of option transactions, and the Service has recently asked for guidance from the tax bar as to what approach it should take. This article focuses on one piece of the partnership option puzzle, options to acquire partnership …