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IRS Publishes Proposed Regulations Applicable to Three-Year Carried Interest Holding Period Requirement

08.05.2020 | Updates On Friday, July 31, 2020, the Internal Revenue Service (IRS) issued proposed regulations under Section 1061 of the Internal Revenue Code. Enacted as part of the 2017 Tax Cuts and Jobs Act, Section 1061...more

IRS Announces Delay of Certain Periods for 1031 Transactions

In response to the ongoing coronavirus pandemic (COVID-19), the Internal Revenue Service (the IRS) has taken additional actions intended to provide immediate relief to taxpayers. Delay of Identification and Acquisition...more

New Three-Year Hold Requirement for Carried Interests, Updated Notice for S Corps

New development: The IRS has issued guidance that the exception to the new 3-year hold requirement for carried interests held by “corporations” does not apply to S corporations. As previously discussed, the 2017 Tax Cuts...more

Private Company Tax Planning Opportunities for 2018

The Tax Cuts and Jobs Act of 2017 (the 2017 Tax Act) and the recent taxpayer victory in the U.S. Tax Court’s Lender Management, LLC decision have created important planning opportunities for both our closely held and...more

New Three-Year Hold Requirement for Carried Interests

The 2017 Tax Cuts and Jobs Act (the Act), signed by President Trump last month, significantly affects the ability of the managers of investment funds to receive long-term capital gains with respect to their carried interest....more

Tax Cuts and Jobs Act of 2017: Year-End Planning for Businesses

The tax reform bill, commonly referred to as the Tax Cuts and Jobs Act of 2017 (the Act), was signed into law on December 22, 2017. The Act contains a number of provisions that create significant year-end planning...more

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