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How hedge and private

equity fund owners can
structure employee
compensation to keep their
superstars

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As any astute business owner knows, superstar employees don’t come cheap. But
without them, profits and that edge over competitors can be elusive. In the highly
competitive world of hedge and private equity funds, how best to compensate
premier talent can be both a daunting and complex balancing act.

Two types of revenue streams

In most cases, hedge and private equity funds have two revenue streams.
1. A fee based on the net assets under management (generally, each investor’s
capital) is usually charged on a quarterly basis and not tied to profits. Many us
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charge 2 percent and call this the management fee. Founder classes or seed
money to get funds going are usually charged less. This income is generally
sourced to the state of its activity, considered Unrelated Business Taxable Income
(UBTI) if received by tax-exempt or pension plan / individual retirement account
entities, subject to self-employment tax, and, if received in New York City by a non-
corporate entity, subject to the Unincorporated Business Tax. As it is taxed at the
highest rate, its cash flow is typically earmarked to pay rent, utilities, payroll,
software services and fixed assets such as computers and desks of the fund.
2. A cut of the profits is variously called the carry, incentive reallocation or carve-out.
Many funds charge 20 percent and sometimes hurdle rates (such as a fixed
percentage or exceeding the federal LIBOR rate) and/or high-water marks (a
partner’s historical losses must be recouped first) are used. There are distinct
advantages of receiving this incentive reallocation from a partnership entity to a
partner. If classified as a share of a partnership’s income as opposed to a payment
to an outside consultant, the profit attributable to unrealized taxable gains is not
taxed currently and the partner is able to take advantage of the lower tax rates
associated with capital gains and qualifying dividends (currently taxed at a highest
federal tax rate of 20%). One downside if the fund is classified as an investor fund
as opposed to a trader, the expenses of the fund (such as professional fees) will be
classified as a portfolio deduction only deductible to the extent they exceed 2
percent of an individual’s Adjusted Gross Income (AGI) and generally are not
deductible for those who end up paying Alternative Minimum Tax (AMT) – so pass-
through of those expenses could have no benefit to the carry vehicle partner. Most
states have a “trading for your own account exception” for purposes of sourcing
so, with exceptions pertaining to sourced income such as loan origination fees, real
estate or oil and gas royalties, this income is sourced to wherever the partner
resides. Generally, this second stream of income would also not be considered
UBTI unless the fund has sourced income or uses leverage. This second stream
and its advantageous tax treatment under current law is one area constantly
under threat of tax reform, albeit that threat has been looming for decades without
actually materializing. In recent years, high performers and senior personnel are
 getting a cut of this stream, where in the past it was usually kept solely with the
fund’s founders. Contact us

Employee vs. partner

Paying an employee a compensation bonus at year-end through a Form W-2 from the
profits of the management company partnership would be the most effective way to
reduce profits of the company that are subject to the self-employment tax (though,
through structuring options, there are ways to minimize the amount of income subject
to that tax) and, if New York City based, the Unincorporated Business Tax. Doing so
would reduce the taxable income of the existing partners. If the management
company uses the accrual method of accounting, the company could accrue these
bonuses at year end and not actually pay out the cash for up to 75 days into the
following year. This delay would not only help with cash flow but also in pinning down
the actual profitability of the company. In the past, these management companies
were typically on the cash basis method of accounting to take advantage of the pre-
2009 deferred compensation rules as they pertained to income from foreign investors
indifferent to the current deductibility of either stream of fees, a benefit that has
largely been eliminated with the implementation of Internal Revenue Code (IRC) §409A
and 457A which will be discussed later. Keep in mind that an accrual-based entity
cannot take an accrued expense if a cash basis related entity does not pick up the
income at the same time under IRC §267. This is often overlooked when a fund pays its
management fee at the end of the quarter as the management company must pick up
the income even if it is not yet paid for the fund investors to be able to take the
expense currently. If the employee is already a junior partner of the management
company, they could also be paid a guaranteed payment bonus that would act the
same way in that it would be deductible to the remaining partners when the junior
partner recognizes the income.

Instead of paying an employee a compensation bonus, they could also receive a

partnership interest in either stream. Tax consequences of receiving a profits
partnership interest or a capital partnership interest differ in that the fair market value
of a capital interest is taxable as consideration upon its reward (that is, if the
partnership liquidated the next minute, what would the new partner get), whereas a
profits interest would generally not be taxable until a share of taxable income is
earned. To prevent future disputes, partnerships should consider having a valuation
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done to quantify the value of the capital interest being awarded and signed off by both
the giver and the recipient. How much say, if any, in partnership management should
be considered and clearly delineated in any such grant of interest to a new partner? If
structured as a profits interest, sometimes “catch-up” provisions are used so that an
interest granted a couple of years into the life of the fund will end up getting a fixed
percentage of the profits of the life of the fund even though they didn’t participate at
first. This generally would be used in the private equity world more than hedge funds.
When receiving a profits interest, the recipient should make a protective IRC 83(b)
election in the event that it is later determined that the interest is actually partially or
completely a capital interest. This would give the recipient capital gain treatment
forward from the time of the election (with the exception of any sale proceeds being
allocated to hot assets as defined under IRC §751 – unrealized receivables and
inventory) and not have any later sale be classified as all compensation. To help the
argument that it is a profits interest and not disguised compensation, the partner
should get some sort of voting rights (the more significant the better).

In either case, the cost and sometimes years of frustration caused by litigation can be
tremendous so it’s in the best interest of everyone in either case to properly
document what is on offer and how future disputes are to be settled. Valuation upon
someone leaving either voluntarily or involuntarily, for instance, can be especially
contentious when thinly-traded, Level 3 assets or the value of a company’s goodwill /
brand name are involved, so exit clauses are essential.

Commonly overlooked issues with partnership

interest grants by the employee
Despite the obvious cachet of being named partner, transitioning from employee to
partner can have consequences the employee should consider before making that
jump. New partners will now be receiving a Schedule K-1 and not a Form W-2 and,
therefore, they will become responsible for payment of their own Social Security and
Medicare taxes as well as any federal or state income taxes. Their tax returns are likely
to become much more complex and may necessitate filing in multiple states and
being responsible for making estimated tax payments to multiple jurisdictions –
additional accounting fees to prepare their returns may not be anticipated especially
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they are receiving a rather minor limited partnership interest. Receiving a partnership
interest in either the entity receiving the carry or the management fee can both trigger
additional state compliance as states grow more and more aggressive in seeking fees
from management fee vehicles through the implementation of market-based
sourcing rules and economic nexus. If foreign entities are used, additional forms may
need to be filed that failing to do so could incur hefty fines – though there is often relief
if certain size thresholds are not met.

Partnership distributions may not mirror taxable income – whether tax distributions
are made should be considered as cash flow, especially in the private equity world,
can be a real concern. Also, coverage for medical insurance and retirement plans is
likely to change as the rules differ for partners versus employees.

As a limited partner, a partner is generally only liable to the extent of his or her capital
account (acceptance to a general partnership suddenly exposes the new partner to
all liabilities of the partnership), but any capital the limited partner contributes is now
an asset of the partnership and could be liable in any lawsuit brought forth, possibly
from an event that transpired before the limited partner was even part of the
company. Oftentimes, a new limited partner is not required to contribute any capital
but that can have its own consequences. To strengthen the argument that both the
carry entity itself in the fund and each partner of the carry entity are indeed partners
and not paid as outside consultants or advisors, most attorneys and accountants
advise partners to have capital at risk. Classification as an outside consultant would
lose all the beneficial attributes of being taxed as a partner – not paying tax on the
unrealized gain and lower tax rate for long term capital gains and qualifying dividends
mentioned above. From the fund standpoint, having partners put their own money in
the fund obviously is more encouragement for the fund to do well. However, from a
risk standpoint, many fund managers take money from the carry vehicle which is
usually classified as the general partner and move it to limited partner interests if they
want to keep the money in the fund and not diversify their holdings. Possibly this move
will prevent loss of their investment as limited partners if one member/partner of the
general partner carry entity commits malfeasance. Contact us

Under the new partnership IRS audit rules that begin on years starting after
December 31, 2017, partnerships with less than 100 partners and no pass through
entities as partners can opt out of the new rules. One of the main benefits of opting
out is that new partners could avoid the possible assessment of tax and penalties for
previous transgressions that the IRS discovers now. Under the new regulations, the
partnership and, therefore, current partners would have to pay the assessed tax for
prior years now. If, however, the management company partnership or carry
partnership did not opt out, a new limited partner to either entity could end up being
penalized for activities that happened before they were partners. Curative allocations
could be done to allocate such penalties to partners who were around at the time of
the year being adjusted but a new limited partner could possibly have no say in
whether those curative allocations had to be done and it might be of a significant
enough size that, even if curative allocations were done, it might take a few years to
even things out because of cash flow or smaller income in the current year.

Privacy and control of information concerns of

existing partners
Even if limited partners are given no voting or governance rights, owners of a
partnership interest can gain access to the partnership tax return. Despite using side
pockets or tranches to isolate a limited partner’s share to a particular revenue stream,
managing partners may not want to give access to overall numbers to a junior partner.
Not giving them a copy of the tax return won’t necessarily prevent a junior partner
from seeing the partnership’s overall tax situation as, being a partner, they can
request a copy of the tax return from the government. Elevating an employee to a
partner also elevates their authority to act on behalf and represent the entity – if
malfeasance were to occur, it’s the possible the partnership may be more liable when
a partner commits the act as opposed to an employee.

If a foreign partner were granted a partnership interest, withholding on the income

might be due by a domestic partnership. The same might be true of states, even on a
domestic partner who lives in another state. These are items to consider before
admitting a partner who may not work or reside in the same area as everyone
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us

Also to consider for the founding partners of a fund before admitting anyone new as a
partner is the long term goal of the partnership. If they ultimately want to sell the
entity, it will be easier and probably more lucrative to not have junior partners to
redeem out or receive consent from regarding a sales price. Obviously, in the infancy
stages of a fund, cash flow may be a concern and offering a partnership interest as a
bonus may be the only way to compensate a high performer.

Entities organized as subchapter S

corporations
Subchapter S corporations can be used instead of partnerships to receive either
stream of income. If the shareholders receive a wage equal to their market value, the
remaining profit has the benefit of not being subject to the self-employment tax.

Many companies, rightly or wrongly, place market value at near to the maximum wage
subject to Social Security tax ($127,200 in 2017). Management companies structured as
limited partnerships to minimize self-employment tax often do the same by giving a
guaranteed payment equal to the same limit and arguing the remaining amount going to
limited partners is a share of ownership-type profits and not in lieu of salary.

S corporations are also not subject to the new partnership rules that begin on January
1, 2018 that may have the effect of penalizing current partners for previous partners’
sins (many of these partnerships, however, may have the option to opt out of the new
rules because of their small size). But S corporations are restricted on who can hold
shares – non-resident aliens, corporations and partnerships cannot. Also, S
corporations can only have one type of share and allocations must be done based on
shares. Side pockets and benchmarks can be used in a partnership.

Bonus tied to individual performance versus

fund overall
To motivate company stability and ensure investor loyalty, generally most funds will
want to align the interests of their employees with those of their customers. Whatever
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form the employee bonus grant takes, funds need to bear in mind the rules and
regulations imposed by the Investment Advisers Act of 1940, the Commodity
Exchange Act, the Dodd-Frank Wall Street Reform and Consumer Protection Act, as
well as various data protection laws.

Tying an employee’s chance for a bonus to solely his or her own portfolio’s
performance and not to the fund overall can have some adverse results. It can
incentivize high risks, possibly cause disputes over resources (researchers or
research information, where to spend money to find deals, marketing, use of limited
capital) and possibly cause unhealthy relationships with other employees managing
separate portfolios that all fold up into one fund.

Example: Before upper management can become aware of the issue, lack of
communication could cause two traders to bet opposite sides of the same position
unintentionally, which can cause adverse tax consequences such as deferment of
recognizing realized losses on wash sales and straddles as tax law applies to the
partnership as a whole and not on each trader’s portfolio.

Example: Two traders could double up on the same positions and put diversification at
risk.

On the other hand, a high performer won’t feel bogged down by other’s bad
performance and feel like all their successes lead to no accompanying reward. If a
fund is employing a variety of portfolios with some used just to manage risk, this might
even be a rather unfair approach depending on which side the employee is called on
to manage. A middle ground can sometimes be achieved by instead having bonus
pools an entire team will participate in. Any of these can be discretionary at the will of
the managing partner or be fixed on ascertainable benchmarks.

Hurdles and high-marks can be used in calculating bonuses similar to those used in
calculating the carry of a fund. Complications to consider, which actually apply to the
carry as well, are numerous. If the fund is actually down but clears the hurdle, are
employees compensated? And what with if there are no profits – is another revenue
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stream, possibly the management fee, tapped? Should the bonus payable percentage
be carried forward? If instead it is carried forward until there are profits, what if the
employee leaves? Does the answer change if the employee dies or becomes
disabled?

Also to be considered when deciding what benchmarks or hurdles to use is how often
money can be withdrawn from a fund. Many hedge funds allow quarterly or monthly
withdrawals which may put undue emphasis on short-term results and not enough on
the long term. This may limit what traders or portfolio managers are willing to invest in.
Obviously, in the private equity arena, this may be less of a concern because
withdrawals may not be allowed for years or until a realized event occurs. But, of
course, the opposite could be true – betting on something long-term when investors
are impatient for more immediate returns.

Restrictions imposed by Internal Revenue Code

§409A and §457A
To defer recognition of taxable income and keep employees invested in the long term
health of a fund, many compensation arrangements make use of some sort of deferral
element. Some firms designate only high earners or holding certain positions as being
able to defer. A floor is usually set below which compensation cannot be deferred. But
to do any of it, two Internal Code Sections must be considered.

Until implementation of IRC §409A and IRC §457A, hedge and private equity managers
had the ability to defer their share of carry, and sometimes management fee, on
foreign investors and/or U.S. tax exempt investors for ten years or more (when using
“back to back” arrangements). This also kept managing partners from paying tax
currently on this deferred income that was earmarked for future employee bonuses
with pre-tax moneys. Employees were sometimes offered this benefit as well on a
pre-tax basis, allowing their future compensation to rise as the foreign fund thrived.
Beginning after 2008, the form of this deferral was changed and “substantial risk of
forfeiture” was then required to continue to defer, meaning if the money was
essentially guaranteed it needed to be picked up in taxable income currently.
Grandfathered plans were required to bring money back into income by 2017. Ifus
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needs to be included under IRC §457A, it is taxed currently and loses its intended
deferral. In distinction, violation of IRC §409A also incurs current taxation but adds a
20% penalty and a premium interest charge. One exception to these rules is provided
in the case of short-term deferrals – once a bonus or fee is no longer subject to a
substantial risk of forfeiture it must be paid within 2 ½ months of year end (March 15 by
calendar year entities). Also, under IRC §457A starting in 2009, offshore funds (and
certain onshore) could no longer pay a fee more than 12 months after the close of the
year in which the services were performed without incurring the 20% penalty and
premium interest charge.

Complicating matters further, not all countries have similar rules to the United States.
So if funds have offshore employees, there might be other issues to deal with. Though
most states conform to the U.S. laws on these topics, fund managers should check if
all the states they receive income from or employee people in do as well.

Vesting: pre-tax dollars versus post-tax dollars

To keep star employees tied to the long term health of a fund and make it harder for
them to leave for greener pastures, their compensation is often tied to a vesting
schedule.

If the bonus is deferred pre-tax, current management company partners must pay
taxes on the compensation not being currently expensed – but they will get a
deduction in the year it is paid. Pre-tax deferrals are, however, the easiest way to
retract if an employee fails to fully vest or forfeits their compensation for any reason. If
the deferred bonus is allowed to grow by tying it to the performance of the fund, the
partners may want to make an equal investment in the fund to hedge against
significant appreciation. A mismatch of cash flow occurs in such a scenario with the
partners. They must invest post-tax funds in the hedge and pay tax currently on the
appreciation of such a hedge until the offsetting compensation is paid off. One way to
mitigate the impact of this mismatch would be to adjust down the appreciation side of
the employee to post-tax, that is if the appreciation is 10 percent and the partners tax
rate is 40 percent - give the employee’s deferred bonus only an appreciation of 6
percent (10% * (1 – 40%)). Contact us

Post-tax bonuses that are required to be reinvested in the fund give current partners a
deduction, but also tax the employee currently on amounts not yet fully vested. This
can be mitigated by tax distributions. Required reinvestment forces an employee to
continue to have skin in the game and contribute to the firm’s success. If large
enough, the amounts might even have an effect on the fund’s ability to continue to find
new deals and perpetuate the fund’s life. Typically, required reinvestment is done
through a separate entity that invests in the fund so that later disputes are handled at
its level and not at the fund’s to keep investors ignorant of such conflicts – this can
also help in meeting the ��accredited investor” and “qualified purchaser” exception
thresholds offered by the Securities Act of 1933 and Investment Company Act of 1940,
though with the expansion of “knowledgeable employees” by the Securities and
Exchange Commission in 2014 this may be less of a concern. Whether or not these
funds are subject to expenses of the fund and redemption restrictions that other
investors share should also be considered. By putting these partners in another entity
they are also probably not able to participate in the management of the fund and
voting.

Pre-tax is generally better for the employee, post-tax perhaps better for the partners
but it requires a lot more work with tax distributions and possibly an additional entity
to form and file tax returns for. Also pre-tax is usually achieved with a single document
whereas post-tax with required reinvestment necessitates vesting schedules and
forfeiture conditions addendums to the limited partnership or limited liability company
agreement.

Vesting: cliff versus graded

The two types of vesting generally used are cliff and graded (or serial). Cliff has the full
amount of compensation vesting all at once on a single future date with forfeiture
usually occurring if the employee leaves beforehand through resignation. The more
common graded has a percentage vesting on a certain date over a certain time period
(for example: one third vesting each December 31 over the next 3 years – up to 5 years
is the period used by most in the industry) with the unvested portion usually being
forfeit if the employee leaves. However, in both cases, the effect of death, disability
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termination without cause should be addressed in the compensation agreement.
Typically an employee must be in good standing with the firm when receiving this
vesting. Obviously, if a new employer matches or exceeds any lost deferred
compensation because it hasn’t vested when he or she leaves, using this tool as a
way to retain high performers is less effective.

Incentives to leave on good terms and paying

out retiring partners
Despite most employment arrangements being “at will,” to encourage employees or
partners who leave a fund to do so on good terms, sometimes severance packages
are offered in exchange for those leaving to sign covenants pledging non-competition,
non-solicitation of investors or employees, non-disparagement and/or non-disclosure
of confidential, proprietary or trade secrets.

To pay out a retiring partner, sunset distributions might be used (which are typically
only available for partners who have been with a firm for certain amount of time).
Instead of buying out a partner in good standing which would result in no deduction
for the remaining partners, the retiring partner could receive a declining interest in net
management fees or the carry over a number of years which would give less taxable
income to the partners that will remain in each of those years but achieve the same
ultimate result. In such an arrangement, the retiring partner is usually given a
corresponding lesser share of proceeds from a possible partnership sale with each
year. Such sunset distributions can be similar to the severance packages listed above
in that they can be a bonus for those leaving who do not compete, solicit employees or
investors, etc.

“Faithless servant” doctrine

The term clawbacks generally refers to some sort compensation being taken back
that might be unvested or vested and still not paid, but can even apply when
payments have been made in certain cases. Any clawbacks implemented must be
cognizant of the “faithless servant” doctrine and how it applies. The “faithless
servant” doctrine says that if an employee’s material and substantial misconduct
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violates his or her contract of service or if he or she has engaged in misconduct that
constitutes a breach of the duty of loyalty or good faith, the employer can recover
compensation already paid. However, not all states follow this and interpretation can
vary even in states that do. Connecticut, Florida and Rhode Island have all rejected the
doctrine. What can further complicate matters is choice of law issues. What happens
when the partnership is organized in Delaware, does most of its business in New York
but has a dispute with a trader who lives in Connecticut? What state’s rule presides?
When drafting employment contracts and partnership agreements, these issues
should be addressed. Recovery of payroll taxes and who’s responsible for that can be
especially burdensome in such cases when clawbacks are implemented.

Other clawbacks
How clawbacks work varies dependent on what revenue stream pays them and
whether the employee is to receive a partnership interest (and no longer be an
employee but now a partner) or just compensation.

Pre-tax clawbacks which would be classified as compensation that has not yet been
paid would generally have no issue since neither side has taken the deduction or the
income into taxable income.

A partnership interest in the management company that does not end up vesting that
is allocated income in years before full vesting presents problems that to date have
not been resolved by any authoritative guidance from the IRS. Under Revenue
Procedure 2001-43, allocating profits to a profits interest in the first year is necessary
even if the partner does not vest until year two to argue that the partnership interest
grant is a profits one and not a capital interest. In the year of the forfeit, the remaining
partners could have ordinary income for the interest they receive from the partner
that did not vest. Presumably the unvested partner would probably receive a capital
loss on its lost partnership interest and the remaining partners would receive ordinary
income to the extent they receive the unvested partner’s interest in the partnership.
However, this result is also an unresolved area of law and taxpayers have been waiting
years for the IRS to provide guidance in this area. Contact us

Profits interests in the carry vehicle that vest over a number of years can be more
complex. In the private equity world, it may take a number of years to earn a carry and,
therefore, if the carry is not earned before an unvested interest is forfeited, there is
probably no effect. If the private equity entity is paying carry currently when granting a
profits interest that would vest over a couple of years or in a typical hedge fund that is
profitable, the answer becomes more difficult. If a graded vesting is used, where the
new partner is entitled to 1 percent of profits in year one, 2 percent in year two, etc.,
the ungraded and unvested profit percentage is simply forfeit. If, however, the new
partner would be entitled to a cliff vesting 5 percent of the profits in year one if he or
she stays two years, the partner would have to pay tax on the full 5 percent of profits
in year one to argue that the interest was a profits interest. If that 5 percent is
forfeited, curative allocations can be used as in the management company. However,
the character may end up different as carry vehicles often do not generate any
ordinary income and losses are sometimes classified as portfolio deductions that
must exceed 2 percent of Adjusted Gross Income to be deductible. Partners that
remain may not be too concerned about a departing partner and the departing
partner may negotiate that their new employer help with the mismatch, but both
should be aware of the mismatch when offering multiple year vesting in a carry vehicle
generating current profit.

Clawbacks of post-tax compensation with required reinvestment, if done and allowed

by local employment law (since payroll taxes will have been paid) should probably be
done post tax as well to avoid disputes over recapture of payroll taxes, income tax
withholding and tax distributions. Forfeitures in these cases, however, seem ripe for
litigation and should probably be avoided.

Options
Options on a partnership profits interest generally have no increase in value prior to
exercise and don’t seem to fit the hedge and private equity fund model. Options on a
capital interest are treated like a stock option but do not qualify for capital gain
treatment. However, private equity companies that operate as LLCs with membership
interests cannot sponsor employee stock ownership plans (ESOPs), grant stock
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options, or provide restricted stock corporations, or otherwise distribute to
employees actual shares or rights to shares. Instead of implementing options, most
funds choose to issue profits interests.

Other perks
Retirement plans with employer matching, medical insurance, life insurance and other
perks such as generous expense accounts or company vehicles can be offered as
well to star employees. These have various issues and drawbacks that are outside the
scope of this article, but keep in mind that the treatment of items such as retirement
plan contributions and medical insurance expense are different for an employee
versus a partner and one cannot be both. For instance, often a partnership will
continue to pay a partner through compensation on a Form W-2 to make sure the
partner withholds enough income taxes each year, but this is not correct and, if
audited, the IRS could disallow the partnership a deduction for its share of the payroll
taxes and any medical insurance paid on the partner’s behalf.

Conclusion
Losing a superstar employee and having to spend time and resources to replace
them, often without a guarantee of their replacement’s equal ability, can be a very
costly endeavor. So the incentive to keep them happy and earning for a fund is
considerable. Through uses of vesting and clawbacks, there are ways hedge and
private equity funds can competitively compensate their top performers while still
maintaining some control of the future. Depending on the fund’s trading strategy, type
of investments and long term goals, bonus packages can be tailored to satisfy both
parties.

For more information on compensation of hedge and private equity fund partners
and employees, or to learn how Baker Tilly asset management industry tax
specialists can help, contact our team.
The information provided here is of a general nature and is not intended to address the
specific circumstances of any individual or entity. In specific circumstances, the
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services of a professional should be sought. Tax information, if any, contained in this
communication was not intended or written to be used by any person for the purpose
of avoiding penalties, nor should such information be construed as an opinion upon
which any person may rely. The intended recipients of this communication and any
attachments are not subject to any limitation on the disclosure of the tax treatment or
tax structure of any transaction or matter that is the subject of this communication
and any attachments.

Related sections

Tax

Private Equity & Portfolio Companies

Federal Tax

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