News & Analysis as of

Capital Gains Proposed Regulation Income Taxes

Gray Reed

IRS Characterizes Monetized Installment Sales as Listed Transaction in Proposed Regulations

Gray Reed on

Monetized installment sale transactions (“MISTs”) have been on the IRS’s radar for some time.  On May 7, 2021, IRS Chief Counsel issued an advice memorandum, contending such transactions were “problematic” and “flawed”. And...more

McDermott Will & Emery

Weekly IRS Roundup July 25 – July 29, 2022

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 25, 2022 – July 29, 2022...more

Jones Day

U.S. Treasury Department Releases Proposed Carried Interest Regulations

Jones Day on

The regulations are proposed to be effective when finalized, but taxpayers may generally rely on them if applied fully and consistently. What Is (and Is Not) Covered? The three-year restriction applies with respect to...more

Neal, Gerber & Eisenberg LLP

Fund Managers and Family Offices Get Some Clarity on Carried Interests with Issuance of Proposed Treasury Regulations

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

Ballard Spahr LLP

Carried Interest – Proposed Regulations and the Impact on Private Equity

Ballard Spahr LLP on

Treasury and the IRS released proposed regulations under Section 1061 of the Internal Revenue Code (the Code) on July 31, 2020, that require certain taxpayers to satisfy a three-year holding period, rather than a one-year...more

Troutman Pepper

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

Troutman Pepper on

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

Ballard Spahr LLP

Carried Interest – Proposed Regulations – Impact on Real Estate: The Good and the Bad

Ballard Spahr LLP on

On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more

Proskauer Rose LLP

Key Takeaways from the Proposed Regulations on Carried Interest

Proskauer Rose LLP on

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

A&O Shearman

Opportunity Zones: Final Regulations Provide Additional Flexibility

A&O Shearman on

On January 13, 2020, the Treasury Department and the Internal Revenue Service published final regulations (the “Final Regulations”) regarding “Qualified Opportunity Zones” (“QOZs”) and “Qualified Opportunity Funds” formed to...more

McDermott Will & Emery

Weekly IRS Roundup December 16 – 20, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

Ballard Spahr LLP

QOZ Update: IRS Provides Relief for Early Investments of Net Section 1231 Gain

Ballard Spahr LLP on

There are many complex and confusing aspects to the qualified opportunity zone (QOZ) program, and the treatment of Section 1231 gain is no exception.  Internal Revenue Code Section 1231 applies to depreciable property and...more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update: New Proposed Treasury Regulations (Part II)

Qualified Opportunity Zone Businesses - BACKGROUND - In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income...more

K&L Gates LLP

Opportunity Zones: Second Round of Proposed Regulations Are Good News For Renewables, But Refinements Are Needed

K&L Gates LLP on

The Opportunity Zones (“OZ”) incentive created in the 2017 Tax Cuts and Jobs Act (the “TCJA”) can be a powerful tool for renewable energy and other industries, as we discussed soon after the TCJA became law. ...more

McDermott Will & Emery

Treasury Provides Additional Guidance on Opportunity Zone Provisions

The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more

Foster Garvey PC

Opportunity Zone Funds – Part IV: The Second Round of Proposed Regulations

Foster Garvey PC on

On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more

Holland & Hart LLP

Proposed Regulations Provide Some Clarity for Opportunity Zone Tax Incentive

Holland & Hart LLP on

The Treasury Department and Internal Revenue Service issued proposed regulations and other guidance on the new "opportunity zone" tax incentive on October 19, 2018. This tax incentive encourages investment in certain...more

Holland & Knight LLP

Opportunity Zone Investments: What You Need to Know and Potential Scenarios - A New Opportunity for Investors to Defer Taxable...

Holland & Knight LLP on

• The Internal Revenue Service (IRS) on Oct. 19, 2018, issued much anticipated proposed regulations (the Proposed Regulations) and other guidance on tax benefits arising from investments in "qualified opportunity zones" that...more

Katten Muchin Rosenman LLP

Qualified Opportunity Zone Proposed Regulations Q&As

On October 19, the Internal Revenue Service (IRS) and US Department of the Treasury released the first set of proposed regulations under Internal Revenue Code Subchapter Z—Opportunity Zones (Proposed Regulations). On the same...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 9, No. 3

Morrison & Foerster LLP on

IRS Issues Proposed Regs on RIC Commodity Investments - On September 27, 2016, the IRS issued proposed regulations (the “Proposed Regulations”) providing guidance relating to the income test and asset diversification...more

Proskauer Rose LLP

Proposed Regulations Issued On Management Fee Waivers

Proskauer Rose LLP on

On July 22, 2015, the U.S. Department of the Treasury and U.S. Internal Revenue Service issued proposed Treasury Regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended, addressing management...more

20 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide