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Structuring Sales of Investments by Funds After the Proposed Section 1061 Regulations

Introduction - Gain of a fund or other investment partnership from a capital asset sale held for over one year is taxed to the fund’s partners at favorable long-term capital gains rates. Until 2018, this general rule...more

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

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

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