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Family Limited Partnership Update, Farhad Aghdami
Family Limited Partnership Update, Farhad Aghdami
William & Mary Annual Tax Conference
No abstract provided.
Proposed Regulations On Noncompensatory Options: A Light At The End Of The Tunnel, Walter D. Schwidetzky
Proposed Regulations On Noncompensatory Options: A Light At The End Of The Tunnel, Walter D. Schwidetzky
All Faculty Scholarship
It has become increasingly common for partnerships to issue options. There is a dearth of authority on the federal tax treatment of options to acquire interests in partnerships. In this context, there are two main categories of options, services options and noncompensatory options. Services options, unsurprisingly, are options to acquire partnership interests where the option is received in exchange for services. Noncompensatory options cover the rest of the waterfront. The simplest version of the latter would be partnership analog to normal options found outside the partnership context: the option holder pays the partnership an option premium to acquire an option …