Interpretation and Application of Target Allocations – In Drafting and In Practice, 29th Annual Texas Federal Tax Institute
29th Annual Texas Federal Tax Institute, June 5-7, 2013
Hyatt Regency Hill County Resort
San Antonio, TX
Interpretation and Application of Target Allocations – In Drafting and In Practice – A practical discussion of the latest issues and mechanics of target allocations in partnership agreements:
- what is a target allocation and how does it compare to traditional “layer cake” allocations;
- how target allocations work and how can the way allocations are drafted affect tax and economics, and
- the pros and cons of using target allocations through a series of real-world examples.
Steven R. Schneider, Washington, D.C.
Phillip Gall, New York, New York
Curtis G. Wilson, Associate Chief Counsel (Passthroughs & Special Industries), Internal Revenue Service, Washington, D.C.