Law360, New York ( August 14, 2014, 11:18 AM EDT) -- There are many reasons why a publicly traded partnership may want to change its equity compensation structure in connection with an initial public offering. Most private partnerships provide equity compensation to their top executives in a manner that is significantly different than private corporations. In particular, partnerships often award key service providers with profits interests that have the potential to result in capital gains treatment. After an IPO, the favorable tax treatment afforded to profits interests is not applicable to a publicly traded partnership. Many private partnerships may also limit grants of equity to high-level executives. Following an offering, a publicly traded partnership may desire a more flexible omnibus equity compensation program that allows the partnership achieve a variety of business goals, including granting awards to a broader class of employees....