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
8/25/2020
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Capital Gains ,
Capital Investments ,
Carried Interest ,
Fund Managers ,
Holding Periods ,
Income Taxes ,
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Investment Management ,
IRS ,
Partnership Interests ,
Partnerships ,
Pass-Through Entities ,
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Proposed Regulation ,
Tax Cuts and Jobs Act ,
U.S. Treasury
Historically, we have advised clients that it is no less advantageous, from a federal income tax perspective, to acquire a partnership interest (including a membership interest in an LLC taxed as a partnership) than it would...more