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Carried Interest APIs

BakerHostetler

Carried Interest Update: Final Regulations Provide Taxpayer-Favorable Rules, but Unanswered Questions Linger

BakerHostetler on

On Jan. 19, 2021, the Internal Revenue Service and the Treasury Department published final regulations on the Section 1061 “carried interest” rules (T.D. 9945). The final regulations generally adopt proposed regulations...more

Cole Schotz

Carried Interests: Final Capital Gain Recharacterization Rules Released

Cole Schotz on

In the 2017 Tax Act, Congress adopted Code §1061, a provision which affects non-corporate holders of certain carried interests, which the new law refers to as applicable partnership interests (“APIs”). Under the new law,...more

Gould + Ratner LLP

IRS Finalizes Carried Interest Regulations

Gould + Ratner LLP on

The IRS and Treasury Department released final regulations on January 7, 2021, that govern the tax treatment of partnership and LLC interests related to services, so-called carried interests, a/k/a applicable partnership...more

Goodwin

Highlights From The Proposed Carried Interest Regulations

Goodwin on

The U.S. Treasury Department and the Internal Revenue Service recently released proposed regulations under Section 1061 of the Internal Revenue Code of 1986, as amended.1 Congress enacted Section 1061 in 2017 in order to...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

BakerHostetler

Proposed Regulations Provide Guidance on Taxation of Carried Interests

BakerHostetler on

On July 31, the IRS and the Treasury Department released long-awaited proposed regulations on the Section 1061 “carried interest” rules. The proposed regulations include extensive definitional and operational rules on the...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

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