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
8/10/2020
/ APIs ,
Capital Gains ,
Capital Gains Tax ,
Carried Interest ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Partnership Interests ,
Partnerships ,
Pass-Through Entities ,
Private Equity ,
Proposed Regulation ,
Recharacterization
On April 23, 2020, the Treasury Department and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 512(a)(6) of the Internal Revenue Code (the “Code”). Section...more