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Carried Interest Tax Rates Tax Planning

Morgan Lewis

Inflation Reduction Act of 2022 Would Alter the Taxation of Carried Interest

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US Senators Joe Manchin and Chuck Schumer announced on July 27 an agreement in principle on a legislative proposal, known as the Inflation Reduction Act of 2022, that includes a range of measures addressing consumer energy...more

Freeman Law

Hedge Funds 101: An Introduction to Tax Issues

Freeman Law on

Hedge Funds and Taxes - Hedge funds provide a vehicle to pool private capital for investment in stocks, securities and financial derivatives. While hedge funds take on many different structures—including master-feeder,...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Cadwalader, Wickersham & Taft LLP

A Look at the House Ways and Means Committee’s Tax Proposals

I. Introduction - On September 15, 2021, the House Ways and Means Committee approved tax provisions for proposed inclusion in the Build Back Better Act (the BBBA). If enacted in their current form, the proposals would,...more

Polsinelli

The House Ways and Means Committee Finally Provides Draft Legislative Language for the Tax Changes First Set Forth in President...

Polsinelli on

In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. On May 28, 2021, the United State Department of Treasury issued a report entitled “General Explanation of...more

Burr & Forman

Summary of Proposed 2021 Federal Tax Law Changes

Burr & Forman on

President Biden has proposed major changes to the Federal tax laws, some of which are sought to be effective earlier in 2021 (i.e., we are already operating under these changes, if they later become adopted), as compared to...more

Proskauer Rose LLP

Hong Kong’s Carried Interest Tax Concession – Zero % Tax!

Proskauer Rose LLP on

Following the enactment last year of the Limited Partnership Fund Ordinance, which has seen strong take up in its first eight months of operation, the new tax concession on carried interest earned from the activities of...more

Polsinelli

A Summary of Potential Tax Increases That Would Occur Under the Proposed American Families Plan

Polsinelli on

On April 28, 2021, the White House issued a fact sheet which set forth some additional details on the tax increase proposals contained in President Biden’s “American Families Plan.” ...more

Cadwalader, Wickersham & Taft LLP

Biden Tax Proposals to Pay for the American Families Plan

On April 28, 2021, President Biden announced the American Families Plan, a $1.8 trillion proposal that would fund a number of education and childcare projects....more

Lowndes

Biden Proposes Tax Hike on Businesses and High-Income Individuals

Lowndes on

Over the last month, President Biden has discussed various tax proposals that will increase income taxes on businesses and high-income individuals. In the last week, we have learned more about what some of those proposals...more

Morgan Lewis

Tax Reform on the Horizon: Current Developments and Updates

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With the recent passage of the COVID-19 stimulus package, President Joseph R. Biden, his administration, and Congress have turned their attention to long-term economic recovery, deficit reduction, and tax reform. ...more

Cadwalader, Wickersham & Taft LLP

Carried Interests in the Crosshairs (Again)

Democrats have proposed a bill to tax carried interests at ordinary income rates. Under current law, fund managers generally recognize income or gain in respect of their carried interests only when the fund sells assets that...more

Cadwalader, Wickersham & Taft LLP

IRS Proposes Carried Interest Regulations

On July 31, 2020, the IRS and Treasury issued proposed regulations under section 1061 of the tax code. Section 1061 imposes a three-year holding period as a precondition to recognizing long-term capital gains on carried...more

Dechert LLP

Hong Kong’s 0% Tax Concession for Carried Interest

Dechert LLP on

After six months of consultation, the Inland Revenue (Amendment) (Tax Concessions for Carried Interest) Bill 2021 ("Bill") providing for a tax concession for a 0% profits tax rate on eligible carried interest ("Tax...more

Kramer Levin Naftalis & Frankel LLP

Final Treasury Regulations Issued Addressing the Application of Section 1061 to Carried Interests (UPDATED)

On Jan. 8, 2021, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued final regulations (Final Regulations) (T.D. 9945) governing the treatment of “carried interests” (also referred...more

Stinson LLP

IRS Issues Final Carried Interest Regulations

Stinson LLP on

The tax treatment of carried interests was changed with the enactment of Section 1061 of the Internal Revenue Code as part of the 2017 Tax Cuts and Jobs Act. After issuing proposed regulations last summer, the Internal...more

Morgan Lewis

IRS Issues Final Regulations on Carried Interests

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The Internal Revenue Service and the US Department of the Treasury pre-released final regulations, T.D. 9945, under Section 1061 on January 7, providing guidance to the holders of certain carried interests. These rules are of...more

Polsinelli

No S-Corp for You? – New Proposed Carried Interest Regulations that May Affect Crypto Fund Managers

Polsinelli on

Historically, the ability for investment fund managers to take profits in the form of carried interest has allowed those managers to pay the lower long-term capital gains tax rate (compared to income) so long as the...more

Kramer Levin Naftalis & Frankel LLP

Long-Awaited Treasury Regulations Address the Application of Section 1061 to Carried Interests

On July 31, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REGS-107213-18) (Proposed Regulations) governing the treatment of “carried interests” (also...more

Stinson LLP

IRS Releases Carried Interest Proposed Regulations

Stinson LLP on

On July 31, the IRS issued proposed regulations under Section 1061 of the Internal Revenue Code further clarifying the tax treatment of carried interest and other "applicable partnership interests" (APIs)....more

Morgan Lewis

IRS Issues Proposed Regulations on Carried Interests

Morgan Lewis on

The Internal Revenue Service (IRS) and the US Treasury Department released proposed regulations (REG-107213-18) under Section 1061 on July 31 providing guidance to the holders of certain carried interests. These rules are of...more

Cozen O'Connor

Proposed Regulations Provide Guidance for the Carried Interest Rules — Six Important Takeaways

Cozen O'Connor on

On Friday, July 31, 2020, the IRS released a Notice of Proposed Rulemaking (Proposed Regulations) setting forth guidance under Code Sec. 1061, the so-called “carried interest” rules. The carried interest rules under Code Sec....more

Ballard Spahr LLP

Treasury Releases Final Regulations On Qualified Opportunity Zone Program

Ballard Spahr LLP on

The U.S. Department of Treasury published Final Regulations for the Qualified Opportunity Zone (QOZ) program on January 13, 2020, which answer many, but not all, of the questions arising from the Proposed Regulations released...more

Polsinelli

Polsinelli Commentary on the Second Round of Opportunity Zone Regulations

Polsinelli on

Treasury issued the long-awaited second round of Proposed Regulations yesterday (April 17, 2019), clarifying some key issues in connection with investing in and forming Qualified Opportunity Funds (“QOF”) and the OZ Fund’s...more

Lowndes

Tax Cut and Jobs Act Limits Benefit of Carried Interest

Lowndes on

After many years of being the target of Congress and the IRS, the Tax Cut and Jobs Act finally succeeded in limiting the beneficial tax treatment of carried interests, at least for some taxpayers. This change will be of...more

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