Income Taxes, Carried Interest

Taxes and the 2024 Election: ‘Tis the Season to Plan and Act

Rivkin Radler LLP on 12/20/2023

This is The End- I have dreaded the year end for as long as I can remember. As a teenager and then as a young adult I associated the final quarter of the year, and especially the period beginning on Thanksgiving and...more

Senate Passes Significant Tax Changes Over the Weekend

Jackson Walker on 8/9/2022

Over the weekend, the U.S. Senate passed H.R. 5376, the Inflation Reduction Act of 2022 (the “Act”) as part of the fiscal year 2022 budget reconciliation bill. The U.S. House of Representatives will consider the Act this...more

Inflation Reduction Act & Long-Term Capital Gain for Carried Interest

McDermott Will & Emery on 8/1/2022

OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more

Congress Proposes Changes to the Taxation of Carried Interest

Clark Hill PLC on 8/1/2022

On July 27, the Senate reached a deal that would raise taxes on carried interest income earned by investment managers. If enacted, the Inflation Reduction Act of 2022 (the “Act”) would amend the relatively new Section 1061...more

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

Morgan Lewis on 7/29/2022

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

New Bill Will Tax Real Estate “Promote” as Carried Interest Subject to Three-Year Holding Period

Goulston & Storrs PC on 7/29/2022

Senators Manchin and Schumer this week announced that the “Inflation Reduction Act of 2022” will be added to the FY2022 Budget Reconciliation bill. The bill includes changes to Section 1061 of the Code (which was added to the...more

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

Foster Garvey PC on 10/15/2021

...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

“Should Five Percent Appear Too Small, Be Thankful I Don’t Take It All”: Ways and Means Committee Advances Tax Increase and Reform...

ArentFox Schiff on 9/23/2021

The House Ways and Means Committee advanced key tax reform proposals on September 15 that would increase taxes for corporations and high-income individuals. Several tax reform proposals are under consideration as part of...more

4 Key Takeaways | Mid-Year Tax Update

Kilpatrick on 8/11/2021

On June 22, 2021, Kilpatrick Townsend Tax attorneys Lynn Fowler, Heather Preston, Rob Daily, and Jeff Reed participated in a mid-year tax update webinar hosted by the firm. The webinar discussed recent tax issues in the...more

4 KEY TAKEAWAYS: Mid-Year Tax Update

Kilpatrick on 7/26/2021

On June 22nd, Kilpatrick Townsend Tax attorneys Lynn Fowler, Heather Preston, Rob Daily, and Jeff Reed participated in a mid-year tax update webinar hosted by the firm. The webinar discussed recent tax issues in the federal...more

American Families Plan and Real Estate Investments–Capital Gains and Carried Interests

Whitman Legal Solutions, LLC on 5/3/2021

Premiering Fanfare for the Common Man near to Tax Day recognized the people’s financial sacrifices to pay for the war effort. Goossens chose tax day because “the common man will be paying his income tax two days later (if he...more

Biden's American Families Plan Proposes Income Tax Hikes

Holland & Knight LLP on 4/30/2021

The American Families Plan is the third part of the Biden Administration's Build Back Better agenda, addressing "human infrastructure" and containing proposals on free education, direct support to children and families, and...more

Highlights From The Final Carried Interest Regulations

Goodwin on 1/27/2021

On January 7, 2021, the U.S. Treasury Department and the Internal Revenue Service released final regulations under Section 1061 of the Internal Revenue Code of 1986, as amended (“the Code”). The Final Regulations address the...more

IRS Finalizes Carried Interest Regulations

Gould + Ratner LLP on 1/25/2021

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

U.S. Treasury Department Releases Proposed Carried Interest Regulations

Jones Day on 9/1/2020

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

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

Neal, Gerber & Eisenberg LLP on 8/25/2020

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

Key Takeaways From the Carried Interest Proposed Regulations

Katten Muchin Rosenman LLP on 8/24/2020

Under current (post-2017) federal income tax law, long-term capital gain allocated to or realized by a non-corporate recipient of a promote or other performance-based allocation (a "Carried Interest") in the investment...more

Carried Interest – Proposed Regulations and the Impact on Private Equity

Ballard Spahr LLP on 8/19/2020

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

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

Troutman Pepper on 8/17/2020

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

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

Ballard Spahr LLP on 8/14/2020

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

Key Takeaways from the Proposed Regulations on Carried Interest

Proskauer Rose LLP on 8/10/2020

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

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 2 - An Overview of the Tax Act's Effects on Various...

Holland & Knight LLP on 7/25/2018

• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more

Income Taxes › Carried Interest