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Internal Revenue Code (IRC) Capital Gains Private Equity

Fox Rothschild LLP

Trump May Revive Effort to Close Carried Interest Loophole

Fox Rothschild LLP on

President Trump is meeting with Republican lawmakers to discuss potential tax code changes, including a proposal to eliminate the carried interest tax break. White House Press Secretary Karoline Leavitt announced the...more

Seward & Kissel LLP

Carried Interest in the Crosshairs…Again

Seward & Kissel LLP on

On February 6, 2025, Democratic Senators and Representatives proposed the Carried Interest Fairness Act, which would treat carried interest as ordinary income. Additionally, on the same day President Trump met with...more

Troutman Pepper Locke

Rolling Over and Section 704(c); What's the Big Deal? — Part 2: The Traditional Method

Troutman Pepper Locke on

In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner. As...more

Jackson Lewis P.C.

Carried Interest/Promote in 2022: Action Items for Investment, Private Equity, Real Estate Fund Managers

Jackson Lewis P.C. on

Investment, private equity, and real estate fund managers should consider becoming familiar with the complex final regulations on the preferential tax treatment of “carried interest” under Section 1061 of the Internal Revenue...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

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

Troutman Pepper Locke

Private Equity and Hedge Fund Managers Take Caution - Proposed Treasury Regulations Threaten Management Fee Waivers

Troutman Pepper Locke on

On July 23, 2015, the Internal Revenue Service ("IRS") issued long-awaited proposed regulations discussing the taxation of management fee arrangements commonly used by private equity funds and their management. The proposed...more

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