Does Ackman really benefit from conversion to a C-corp? As a 10% owner/manager, he is not subject to PFIC tax restrictions. Additionally, Pershing continually buys back shares and pays out cash, concentrating his holdings. So he personally benefits enormously both from the management/performance fees AND from the discount. When he choses…
Does Ackman really benefit from conversion to a C-corp? As a 10% owner/manager, he is not subject to PFIC tax restrictions. Additionally, Pershing continually buys back shares and pays out cash, concentrating his holdings. So he personally benefits enormously both from the management/performance fees AND from the discount. When he choses to retire or at his demise, Pershing will liquidate, closing the discount, and maximizing benefits to Bill and his family/estate. If as an investor you are fully committed to an indefinite hold, you would benefit from the discount as well...but closure may be decades away.
Does Ackman really benefit from conversion to a C-corp? As a 10% owner/manager, he is not subject to PFIC tax restrictions. Additionally, Pershing continually buys back shares and pays out cash, concentrating his holdings. So he personally benefits enormously both from the management/performance fees AND from the discount. When he choses to retire or at his demise, Pershing will liquidate, closing the discount, and maximizing benefits to Bill and his family/estate. If as an investor you are fully committed to an indefinite hold, you would benefit from the discount as well...but closure may be decades away.