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 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 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
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
On Jan. 8, 2021, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued final regulations (Final Regulations) (T.D. 9945) governing the treatment of “carried interests” (also referred...more
Historically, the ability for investment fund managers to take profits in the form of carried interest has allowed those managers to pay the lower long-term capital gains tax rate (compared to income) so long as the...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
Treasury issued the long-awaited second round of Proposed Regulations yesterday (April 17, 2019), clarifying some key issues in connection with investing in and forming Qualified Opportunity Funds (“QOF”) and the OZ Fund’s...more
After many years of being the target of Congress and the IRS, the Tax Cut and Jobs Act finally succeeded in limiting the beneficial tax treatment of carried interests, at least for some taxpayers. This change will be of...more
Friday’s jobs report underwhelmed, but it shouldn’t necessarily put off a June rate hike by the Fed, says the Journal, especially given the news that wages climbed last month – WSJ... Fair Game got downright monarchical...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
Last week, I was at the ABA Tax Section meeting in Chicago. During one of the partnership panels, Clifford Warren, Special Counsel to the Associate Chief Counsel (Passthroughs and Special Industries) at the IRS, was posed...more