News & Analysis as of

Capital Gains Internal Revenue Service Proposed Regulation

Fox Rothschild LLP

IRS Issues Basis Shifting Guidance for Partnerships, Proposes Reporting Requirements

Fox Rothschild LLP on

The Internal Revenue Service (IRS) and U.S. Department of Treasury recently issued guidance to curtail what they consider abusive basis shifting by related-party partners and partnerships. That guidance, which was issued June...more

Rivkin Radler LLP

Partnership Losses on Related Party Sales – The IRS Provides Some Clarification

Rivkin Radler LLP on

Few individual owners of a closely held business would be surprised if you explained to them that the IRS and the Federal courts generally will subject many transactions between certain “related” persons to heightened...more

Allen Barron, Inc.

The US Treasury Department and IRS Have Released New Proposed Regulations on Sales and Exchanges of Digital Assets

Allen Barron, Inc. on

The US Treasury Department and the IRS have released new proposed regulations on sales and exchanges of digital assets such as cryptocurrencies and Non-Fungible Tokens or NFTs. What taxes would a US taxpayer owe associated...more

Gray Reed

IRS Characterizes Monetized Installment Sales as Listed Transaction in Proposed Regulations

Gray Reed on

Monetized installment sale transactions (“MISTs”) have been on the IRS’s radar for some time.  On May 7, 2021, IRS Chief Counsel issued an advice memorandum, contending such transactions were “problematic” and “flawed”. And...more

McDermott Will & Emery

Weekly IRS Roundup July 25 – July 29, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 25, 2022 – July 29, 2022...more

Eversheds Sutherland (US) LLP

Proposed regulations issued under section 1256 with respect to foreign currency options

Section 1256 generally requires that certain contracts, including “foreign currency contracts,” be marked-to-market annually. The Internal Revenue Service (IRS) has long maintained that foreign currency options are not...more

Lowndes

Bipartisan Bill Proposes Changes to Opportunity Zone Benefits

Lowndes on

If you acquired or built a senior living facility that is located in an opportunity zone, or are considering doing so, a recent bipartisan bill introduced in Congress proposes making changes to the opportunity zone rules. ...more

Cole Schotz

Carried Interests: Final Capital Gain Recharacterization Rules Released

Cole Schotz on

In the 2017 Tax Act, Congress adopted Code §1061, a provision which affects non-corporate holders of certain carried interests, which the new law refers to as applicable partnership interests (“APIs”). Under the new law,...more

Jones Day

U.S. Treasury Department Releases Proposed Carried Interest Regulations

Jones Day on

The regulations are proposed to be effective when finalized, but taxpayers may generally rely on them if applied fully and consistently. What Is (and Is Not) Covered? The three-year restriction applies with respect to...more

Goodwin

Highlights From The Proposed Carried Interest Regulations

Goodwin on

The U.S. Treasury Department and the Internal Revenue Service recently released proposed regulations under Section 1061 of the Internal Revenue Code of 1986, as amended.1 Congress enacted Section 1061 in 2017 in order to...more

Neal, Gerber & Eisenberg LLP

Fund Managers and Family Offices Get Some Clarity on Carried Interests with Issuance of Proposed Treasury Regulations

On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more

McDermott Will & Emery

IRS Issues Proposed Regulations Intended to Clarify Carried Interest Rules

McDermott Will & Emery on

The Internal Revenue Service (IRS) recently issued proposed regulations under section 1061, a provision enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA) that recharacterizes certain net long-term capital gain with...more

Ballard Spahr LLP

Carried Interest – Proposed Regulations and the Impact on Private Equity

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Treasury and the IRS released proposed regulations under Section 1061 of the Internal Revenue Code (the Code) on July 31, 2020, that require certain taxpayers to satisfy a three-year holding period, rather than a one-year...more

Troutman Pepper

Proposed Regulations Shed Light on Three-Year Holding Period Requirement for Carried Interest

Troutman Pepper on

Introduction and Background - Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more

Ballard Spahr LLP

Carried Interest – Proposed Regulations – Impact on Real Estate: The Good and the Bad

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On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more

White & Case LLP

Overview of the Carried Interest Rules and the Proposed Regulations

White & Case LLP on

On July 31, 2020, the U.S. Internal Revenue Service (the "IRS") and the U.S. Treasury Department ("Treasury") issued proposed regulations (the "Proposed Regulations") that provide taxpayers with definitional and computational...more

Dechert LLP

Proposed Carried Interest Regulations: Treasury Carries the Ball, Giving Precious Few Points to Fund Managers

Dechert LLP on

The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) on July 31, 2020 issued long-awaited proposed regulations (the “Proposed Regulations”) providing guidance under section 1061...more

Proskauer Rose LLP

Key Takeaways from the Proposed Regulations on Carried Interest

Proskauer Rose LLP on

On July 31, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) providing guidance on Section 1061 of the Code, as...more

Proskauer - Tax Talks

 “Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

Proskauer - Tax Talks on

On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more

McGlinchey Stafford

IRS Proposes New Like-Kind Exchange Regulations

McGlinchey Stafford on

The 2017 Tax Cut and Jobs Act (TCJA) limited like-kind exchanges occurring after 2017 to “real property held for productive use in a trade or business or investment if such real property is exchanged for real property of a...more

Jackson Walker

Treasury Releases Final Regulations for Investing in Qualified Opportunity Zones

Jackson Walker on

On December 19, 2019, the Treasury Department released final regulations on the Qualified Opportunity Zone (QOZ) program first enacted in the Tax Cuts and Jobs Act of 2017. Final regulations provide additional safe harbors...more

A&O Shearman

Opportunity Zones: Final Regulations Provide Additional Flexibility

A&O Shearman on

On January 13, 2020, the Treasury Department and the Internal Revenue Service published final regulations (the “Final Regulations”) regarding “Qualified Opportunity Zones” (“QOZs”) and “Qualified Opportunity Funds” formed to...more

McDermott Will & Emery

Weekly IRS Roundup December 16 – 20, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

McDermott Will & Emery

Weekly IRS Roundup October 28 – November 1, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 28 – November 1, 2019. October 30, 2019: The IRS issued an Action on Decision in which...more

Obermayer Rebmann Maxwell & Hippel LLP

Part I: Qualified Opportunity Fund Tax Benefits – Not Just For Real Estate Investors

The Treasury Department has issued two sets of proposed regulations concerning the tax benefits available to taxpayers who invest in Qualified Opportunity Funds (QOFs). The first set of proposed regulations (published in...more

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