The UK tax regime for carried interest is being substantially revised from April 2026. This Alert focuses on one particular aspect: the changes to how credit funds should calculate the average holding period (AHP) of their...more
On July 21, 2025, HM Revenue and Customs (HMRC) published the long-awaited draft legislation (Draft Legislation) for the new UK carried interest tax regime (New Regime) that will apply from April 6, 2026. Under the New...more
On October 10, Representative Matt Cartwright (D-PA) introduced the Bill Pascrell Ending Tax Giveaway Act with the goal of “closing the controversial carried interest loophole.”...more
On Wednesday 30 October 2024, the UK government announced changes to the UK taxation of carried interest as part of the 2024 Autumn Budget. Changes were expected following statements made by the Labour Party in the run up to...more
The Chancellor’s announcement on Wednesday that the UK’s capital gains tax (CGT) rate for carried interest would be increased by only a few percentage points from 28% to 32%, effective April 2025, was welcome news to many....more
Rachel Reeves, the first female Chancellor of the Exchequer in the role’s 800-year history, delivered Labour’s first budget in 14 years on the 30th October. We have set out below a brief summary of some of the tax measures...more
Yesterday, 30 October 2024, the Chancellor announced that the Autumn 2024 budget will raise taxes by £40bn, the biggest raise since 1993. While the Autumn budget arguably does not portray as pessimistic an outlook for...more
The real estate sector was not ignored by Budget announcements today. There were no seismic changes – the changes announced were less impactful than the speculation in the weeks preceding the Budget....more
Recent publicity around the UK taxation of carried interest may, in due course, make it more likely that a UK government would look again at the tax rules around carried interest. ...more
OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more
US Senators Joe Manchin and Chuck Schumer announced on July 27 an agreement in principle on a legislative proposal, known as the Inflation Reduction Act of 2022, that includes a range of measures addressing consumer energy...more
Senators Manchin and Schumer this week announced that the “Inflation Reduction Act of 2022” will be added to the FY2022 Budget Reconciliation bill. The bill includes changes to Section 1061 of the Code (which was added to the...more
Hedge Funds and Taxes - Hedge funds provide a vehicle to pool private capital for investment in stocks, securities and financial derivatives. While hedge funds take on many different structures—including master-feeder,...more
...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more
Following the enactment last year of the Limited Partnership Fund Ordinance, which has seen strong take up in its first eight months of operation, the new tax concession on carried interest earned from the activities of...more
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
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
Hong Kong’s private funds industry is on the verge of benefitting from further significant changes in local laws designed to make Hong Kong more attractive as a centre for private funds and their managers. On 31 August 2020,...more
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
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
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
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
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
A bill recently introduced in the New York State Assembly would impose additional tax on carried interest. The taxation of carried interest has been widely discussed over the last decade, with a number of bills introduced...more
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