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Inflation Reduction Act & Long-Term Capital Gain for Carried Interest

OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more

IRS Issues Proposed Regulations Intended to Clarify Carried Interest Rules

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

CARES Act Five-Year NOL Carryback Rules Will Have Significant Impact on M&A Transactions

The CARES Act bring changes to the net operating loss rules that may impact completed and future corporate transactions...more

IRS Proposes Section 163(j) Regulations – New Business Interest Expenses Deduction Limit

On November 26, 2018, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) pursuant to section 163(j). Public Law 115-97, the Tax Cuts and Jobs Act (TCJA), amended Internal Revenue Code (Code)...more

IRS Publishes Proposed Section 199A Regulations

The IRS recently issued proposed regulations under Section 199A, a provision enacted as part of tax reform to allow individuals and certain other non-corporate taxpayers to deduct up to 20 percent of qualified business...more

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