News & Analysis as of

Proposed Regulation Capital Gains Carried Interest

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

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

McDermott Will & Emery

IRS Issues Proposed Regulations Intended to Clarify Carried Interest Rules

McDermott Will & Emery on

The Internal Revenue Service (IRS) recently issued proposed regulations under section 1061, a provision enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA) that recharacterizes certain net long-term capital gain with...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

Troutman Pepper

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

Troutman Pepper 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

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

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

Dechert LLP

Proposed Carried Interest Regulations: Treasury Carries the Ball, Giving Precious Few Points to Fund Managers

Dechert LLP on

The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) on July 31, 2020 issued long-awaited proposed regulations (the “Proposed Regulations”) providing guidance under section 1061...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

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update New Proposed Treasury Regulations (Part III)

Qualified Opportunity Funds - The Opportunity Zone tax incentive program allows taxpayers that invest in a Qualified Opportunity Fund to (i) defer paying taxes on the capital gain from the sale or exchange of appreciated...more

Akin Gump Strauss Hauer & Feld LLP

Latest Opportunity Zone Rules Clarify Issues Related to Fund Structuring, Qualifying Businesses and Business Property

• The latest set of proposed opportunity zone (OZ) regulations (the “2019 proposed regulations”) provide much-needed flexibility with regard to qualified opportunity funds (“OZ Funds”) and expand the types of businesses and...more

Goulston & Storrs PC

Qualified Opportunity Zones: New Proposed Regulations Provide Further Guidance

Goulston & Storrs PC on

The Treasury Department has now released a second round of proposed regulations on the Qualified Opportunity Zone (“QOZ”) provisions under Internal Revenue Code Section 1400Z-2....more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update: New Proposed Treasury Regulations (Part I)

In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income communities designated by the IRS as qualified opportunity zones....more

Proskauer - Tax Talks

The Second Set of Proposed Opportunity Zone Regulations

Proskauer - Tax Talks on

Introduction - On April 17, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued a second set of proposed regulations (the “Proposed Regulations”) under section...more

Flaster Greenberg PC

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

Flaster Greenberg PC on

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

Latham & Watkins LLP

Draft UK Income-based Carried Interest Legislation Published

Latham & Watkins LLP on

Proposed new UK rules will tax carried interest in certain funds as income, with only specified funds entitled to capital gains treatment - The UK government published draft legislation on 9 December 2015 amending the...more

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