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
8/10/2020
/ APIs ,
Capital Gains ,
Capital Gains Tax ,
Carried Interest ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnership Interests ,
Partnerships ,
Pass-Through Entities ,
Private Equity ,
Proposed Regulation ,
Recharacterization
Introduction -
On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section...more
4/30/2019
/ Anti-Abuse Rule ,
Capital Gains ,
Carried Interest ,
Holding Periods ,
Opportunity Zones ,
Original Use ,
Partnerships ,
Preamble ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments ,
REIT ,
Reporting Requirements ,
S-Corporation ,
Safe Harbors ,
Tax Cuts and Jobs Act
On February 9th, President Obama released his Budget Proposals for 2017 (the "Budget Proposals"). The Budget Proposals include the following proposals that may affect private investment fund managers...more