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
The final regulations addressing the GILTI high-tax exception retain the general approach of the proposed regulations with some simplifying changes.
Key Points:
..Taxpayers can elect on an annual basis whether to...more
Considerable thought and commentary has been given to the numerous technical features introduced by P.L. 115-97 (Dec. 22, 2017), colloquially referred to as the “Tax Cuts and Jobs Act” (the “TCJA”). Nearly one-and-a half...more