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Internal Revenue Service Carried Interest U.S. Treasury

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
DLA Piper

REIT Tax News - March 2025

DLA Piper on

Welcome to the March 2025 issue of REIT Tax News. Below, we summarize five key developments impacting REITs this past quarter. Carried interest favorable taxation may be in jeopardy - On February 6, 2025, President Donald...more

Dorsey & Whitney LLP

President Trump Seeks to End Carried Interest Tax Preference

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President Trump met with Republican lawmakers on Thursday, February 6, 2025, to outline his tax priorities, including extending the 2017 tax cuts and expanding the state and local tax deduction. Also included among the...more

Morrison & Foerster LLP

Proposed “Inflation Reduction Act” Could Significantly Curtail Carried Interest Tax Benefits

On July 27, 2022, Senate Majority Leader Chuck Schumer and Senator Joe Manchin announced their agreement on proposed legislation (the “Inflation Reduction Act of 2022” or “Act”) that is expected to be considered by the Senate...more

Paul Hastings LLP

Proposed Legislation Threatens to Upend Carried Interest Rules

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As widely reported, on July 27, 2022 Democratic Majority Leader Senator Chuck Schumer and Senator Joe Manchin (D-W.Va) agreed to a reconciliation bill package titled the Inflation Reduction Act of 2022. The bill contains...more

Williams Mullen

IRS Releases Finalized Regulations Regarding Taxation of Carried Interest

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The U.S. Department of Treasury and the Internal Revenue Service recently issued final regulations (“the Final Regulations”) regarding certain aspects of so-called carried interest under Section 1061 of the Internal Revenue...more

Latham & Watkins LLP

Final Carried Interest Regulations: Key Takeaways for Private Fund Sponsors

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While the final regulations simplify key exceptions and contain favorable changes, ambiguity continues for investment fund managers. On January 7, 2021, the US Treasury Department and Internal Revenue Service (together,...more

Goodwin

Highlights From The Final Carried Interest Regulations

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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

Troutman Pepper Locke

IRS Issues Final Regulations on Partnership Carried Interests

Troutman Pepper Locke on

On January 13, 2021, the Internal Revenue Service (“IRS”) and the U.S. Treasury Department (“Treasury”) issued the official version of Final Treasury Regulations (the “Final Regulations”) providing guidance under the “carried...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

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

Proskauer - Tax Talks

Section 1061 Final Regulations on the Taxation of Carried Interest

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On January 7, 2021, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations (the “Final Regulations”) providing guidance on Section 1061 of the Internal...more

Mintz - Real Estate, Construction &...

IRS Issues Final Regulations on Taxation of Carried Interest Under Section 1061

On January 7, 2021, the Internal Revenue Service (the “IRS”) and the Department of the Treasury released final regulations (the “Final Regulations”) implementing the provisions of Section 1061 of the U.S. Internal Revenue...more

Jones Day

U.S. Treasury Department Releases Proposed Carried Interest Regulations

Jones Day on

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

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

Neal, Gerber & Eisenberg LLP

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

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

Herbert Smith Freehills Kramer

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

Latham & Watkins LLP

Proposed Carried Interest Regulations Leave Unanswered Questions

Latham & Watkins LLP on

While the proposed carried interest regulations clarify key aspects, the proposed rules leave some ambiguity for investment fund managers. Section 1061 is intended to limit long-term capital gain treatment attributable to...more

Troutman Pepper Locke

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

Troutman Pepper Locke 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

White & Case LLP on

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

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

Flaster Greenberg PC

The Biggest Surprise in the QOZ Regs Is How Many Surprises There Are

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Those following the developments in the world of Qualified Opportunity Zones—those tax benefits derived from investing in economically disadvantaged areas—will already know that the highly anticipated second set of proposed...more

Holland & Knight LLP

Congress Releases Revised Conference Bill on Tax Reform - A Look at How It Compares with Earlier House and Senate Bills

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Congress released the "Tax Cuts and Jobs Act" on late Friday evening, Dec. 15, 2017. This version of the bill is the result of a conference committee process to marry the different bills previously passed by the U.S. House of...more

McGuireWoods LLP

Tax Policy Update

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The top estate tax rate under Democratic presidential candidate Bernie Sanders’ proposal to tax the wealthiest Americans and narrow income inequality in the U.S. The proposal splits the estate tax into four brackets...more

Lowndes

Senator Targets Carried Interests

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Wednesday, Senator Al Franken sent a letter to the Department of Treasury taking aim at “carried interest” income. In the letter, Senator Franken asked the IRS to revise Form 1065 (the tax return form for partnerships) to...more

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