FDH Tax Team Authors Connecticut Bar Association Comments to IRS Proposed Management Fee Waiver Regulations

October 8, 2015

The FDH Tax department (Michael Spiro, Brett Dixon and Jordan Fieldstein) has authored a letter to the US Department of the Treasury on behalf of the Connecticut Bar Association (“CBA”) commenting on proposed tax regulations aimed at curbing the utilization of “management fee waivers” by private equity funds (the “Proposed Regulations”).  The CBA comments recommend that the Proposed Regulations be substantially narrowed so as to relate to only those arrangements where a purported equity interest issued to a fund manager lacks significant risk of loss or opportunity for gain.  A copy of the comment can be found here.