The column, by PricewaterhouseCoopers LLP tax professionals Monte Jackel and Bob Crnkovich, appears for the first time in today’s issue of Tax Notes, the weekly magazine on federal tax policy and administration, and it will also appear tomorrow in Tax Notes Today, the daily online publication on the same topics.
Jackel, a managing director at PricewaterhouseCoopers Washington National Tax Services (WNTS) in Washington DC, often writes and speaks publicly about partnership taxation. He has held several positions with the IRS Chief Counsel’s national office in Washington and the Treasury Department's Office of Tax Policy.
Crnkovich, a principal with PricewaterhouseCoopers Washington National Tax Services in Washington, also writes and speaks about partnership tax matters. He is an adjunct professor at the Georgetown University Law Center, where he teaches the Advanced Partnership Taxation and Private Equity and Hedge Fund courses.
The new column will address current topics of interest in partnership taxation and provide perspectives on the current state of the law, recent developments in IRS guidance and case law, recent legislative developments, and perspectives on where Congress should change the law to address issues and problems of interest to practitioners and the government.
Today’s column examines timing and character issues regarding certain deferred compensation arrangements. Specifically, it focuses on the timing issues surrounding partnership allocations as deferred compensation under sections 409A and 457A, and character issues surrounding partnership allocations under recently proposed legislation in the area of carried interest.
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