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Capital Gains Proposed Regulation Real Estate Investment Trust

Jones Day

U.S. Treasury Department Releases Proposed Carried Interest Regulations

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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

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

White & Case LLP

Overview of the Carried Interest Rules and the Proposed Regulations

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On July 31, 2020, the U.S. Internal Revenue Service (the "IRS") and the U.S. Treasury Department ("Treasury") issued proposed regulations (the "Proposed Regulations") that provide taxpayers with definitional and computational...more

Dechert LLP

Proposed Carried Interest Regulations: Treasury Carries the Ball, Giving Precious Few Points to Fund Managers

Dechert LLP on

The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) on July 31, 2020 issued long-awaited proposed regulations (the “Proposed Regulations”) providing guidance under section 1061...more

Proskauer - Tax Talks

 “Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

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On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more

A&O Shearman

Opportunity Zones: Final Regulations Provide Additional Flexibility

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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

Goulston & Storrs PC

Qualified Opportunity Zones: New Proposed Regulations Provide Further Guidance

Goulston & Storrs PC on

The Treasury Department has now released a second round of proposed regulations on the Qualified Opportunity Zone (“QOZ”) provisions under Internal Revenue Code Section 1400Z-2....more

Proskauer - Tax Talks

The Second Set of Proposed Opportunity Zone Regulations

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Introduction - On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section...more

Verrill

Opportunity Fund Investors Prepare to Zone-In

Verrill on

Treasury Provides Additional Clarity on Opportunity Zones by Issuing Second Round of Proposed Regulations - On April 17, 2019, the U.S. Department of the Treasury issued its second set of proposed regulations (the “New...more

King & Spalding

IRS and Treasury Release Second Round of Qualified Opportunity Zone Guidance

King & Spalding on

On April 17th, the IRS and Treasury issued the next (and long-awaited) package of proposed regulations (the “Proposed Regulations”) under the “qualified opportunity zone” provisions of Section 1400Z-2 of the Code...more

A&O Shearman

Opportunity Zones: Government Issues Proposed Regulations

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On Friday, October 19, 2018, the Treasury Department and the Internal Revenue Service issued highly-anticipated proposed regulations regarding “Qualified Opportunity Zones.” The Qualified Opportunity Zone regime was...more

Morrison & Foerster LLP

MoFo Tax Talk - Volume 9, No. 3

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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

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

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