Business succession planning with carried interests

Richard B. Robinson (Shareholder, Robinson, Diss and Clowdus, P.C., Denver, Colorado) has recently published his article entitled Business Succession Planning, Profits Interests and § 2701, 34 ACTEC J. 243 (2009).

Here is the editors’ synopsis of his article:

This article analyzes the creation and implementation of a type of business succession vehicle that rarely garners the attention it deserves: a profits interest in a partnership–sometimes referred to as a “carried interest.” The article examines the income tax and gift tax minefields that can arise in connection with partnership profits interests, particularly the troublesome IRC Section 2701 issues. Embedded in the article are several helpful examples.