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SUMMARY:Seminar with Michael Knoll\, University of Pennsylvania
DESCRIPTION:Seminar with Michael Knoll\n\nMichael Knoll will present a
  seminar on Thursday\, May 20 at 2\:30 in room 214.  Professor Knoll i
 s the Theodore K. Warner Professor of Law at the University of Pennsyl
 vania Law School and Professor of Real Estate at the Wharton School.  
 He will be discussing his research on the taxation of carried interest
 s at a gathering jointly sponsored by Smeal's Insurance and Real Estat
 e Department and the Dickinson School of Law.  The abstract is below. 
  Please contact Dan Cahoy (DanCahoy@psu.edu) with any questions.\n \nT
 he Tax Advantage of "Sweat Equity"\:\nWhat it is and its Relationship 
 to the Carried Interest Controversy\n \nMichael S. Knoll\nUniversity o
 f Pennsylvania\n\nA central feature in the ongoing controversy over th
 e tax treatment of carried interests is the tax treatment of "sweat eq
 uity". Both reformers\, who want to raise the tax levied on carried in
 terests\, and defenders of the status quo use analogies and comparison
 s to bolster their arguments. Reformers argue that carried interests a
 re improperly being taxed more favorably than are paid services. They 
 argue that private equity fund managers\, who pay tax upon realization
  at long-term capital gains rates\, are taxed less heavily than people
  who are paid salaries and invest their after-tax salaries in equities
 . In response\, defenders of the status quo argue that carried interes
 ts should be taxed no less favorably than "sweat equity" – services 
 provided by an owner of a business that are not compensated by current
  salary – which they assert is taxed as favorably as private equity 
 currently is\, but which they claim would be taxed more favorably than
  private equity if any of the various tax reform proposals were adopte
 d. Thus\, "sweat equity" is at the center of the controversy over the 
 tax treatment of carried interests. Yet\, in spite of the numerous cla
 ims being made about the tax advantage of "sweat equity\," both on its
  own and relative to other forms of compensation\, no one has spelled 
 out carefully and specifically what is the tax advantage from "sweat e
 quity." This essay identifies the source of the tax advantage from usi
 ng "sweat equity." It\, then\, relates that advantage to the carried i
 nterest controversy.
LOCATION:214 Business Building
PRIORITY:3
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