Proc. Today our sister website, Tax-Charts.com, uploaded a free flowchart that deals with the taxation of profits interests under Rev. Rev. Compensation Income Under IRC Section 83, the grant of a capital interest is treated as current compensation to the recipient in an amount equal to the fair market value of the capital interest. Proc.”) 93-27 provides a safe harbor for certain issuances of profits interests that will not be treated as taxable events for the partner or the partnership. Proc. Proc. Revenue Procedure (“Rev. 343) by pro­viding guidance on the treatment of the grant of a partnership profits interest that is substantially nonvested for the provi­sion of services to or for the benefit of the partnership. Revenue Procedure 2001–43 SECTION 1. 93-27 is subject to current tax as compensation in an amount equal to the excess of the interest’s fair market value over the amount paid for the interest. 191, issued by the Internal Revenue Service. Proc. The flowchart can be found here. SECTION 2. 93-48 (notional principal contracts).03 Notice 89-15 (long-term contracts) SECTION 15. Proc. 93-27 and in situations that are described in Rev. PURPOSE This revenue procedure clarifies Rev. Nevertheless, the revenue procedure states that it is a clarification of Rev. 93-27 made in Rev. 93- 27 does not This form is drafted assuming that the entity granting the profits interest is … Proc. 92-20 SECTION 14. Reg. Proc. Proc. 93-27 while extending a similar safe harbor to unvested interests as long as the following conditions are met: 1. 2001-43, which clarified the safe harbor provided in Rev. PAPERWORK REDUCTION … Under Rev. EFFECT ON OTHER DOCUMENTS .01 Rev. Proc. Proc. INQUIRIES SECTION 13. The IRS followed with Rev. 2001-43, regarding the receipt of partnership interests that are not yet vested (as defined in Treas. Proc. 93-27, 1993-2 C.B. Proc. SECTION 12. Proc. 343, as clarified by Rev. a safe harbor profits interest grant (in accordance with Rev. Proc. 93-27 and Rev. Modification of Revenue Procedure 93-27 . The revenue procedure does not contain an effective date. The parties intend that the Profits Interest Units issued pursuant to this Agreement constitute “profits interests,” as described in Section 4.01 of Rev. §1.83-3(b)). Proc. Proc. AlthoughRev.Proc.93-27waswidelyapplauded,substantialquestionsremained,partic-ularlyinregardtotherelationshipofRev.Proc.93-27withSection83.Forexample, 93-27. 2001-43) will impact the recipient. Rev. Rev. BACKGROUND Rev. Proc. Proc. Proc. 93-27). 92-20.02 Rev. Rev. The receipt of a profits interest that does not meet the requirements of Rev. Proc. Proc. EFFECTIVE DATE .01 In general.02 Transition rules (1) Currently pending Forms 3115 (2) New Forms 3115 (3) Open window periods under Rev. 2001-43, 2001-34 I.R.B. granted (Rev. 201943 for certain changes from an impermissible to a - permissible method of depreciation. 93-27. (See Rev. Proc. 2020-25 allows both the QIP accounting method change and an accounting method change to revise one or more of the specified elections to be filed on the same Form 3115 along with a change made under section 6.01 of Rev. 93-27, clarified by Rev. Proc. 93–27 (1993–2 C.B. 93-27, the receipt of a profits interest for services rendered by a partner is taxable in three situations. The flowchart includes the clarifications of Rev. Rev. Both the partnership and the service provider treat the service provider as a … 93-27, as clarified by Rev. Absent a special election, the receipt of a capital interest is generally taxable when Proc. Proc. As such, it should apply retroactively. 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