TaxProf Blog

Editor: Paul L. Caron, Dean
Pepperdine University School of Law

Tuesday, December 4, 2018

Johnson, Kahn & Kahn Debate The Proper Tax Treatment Of Carried Interest

Calvin Johnson (Texas), Jeffrey Kahn (Florida State) & Douglas Kahn (Michigan), Debate on Carried Interest, 157 Tax Notes 1597 (Dec. 11, 2017):

In this point-counterpoint article, Johnson argues that the rationales offered by Professors Douglas and Jeffry Kahn do not justify giving fund managers capital gain treatment for carried interests [Douglas Kahn (Michigan) & Jeffrey Kahn (Florida State), The Fallacious Objections to the Tax Treatment of Carried Interest, 20 Fla. Tax Rev. 319 (2017)]. Johnson argues that the manager's return is entirely labor income, and that the manager has no capital or basis that causes their gains. Partnership taxation should not be available to hide partner-level compensation. The Kahns respond to that contention and defend their position.

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