Exploring Carried Interest in Upper Tier Private Equity Structures — PE Pathways
4 Key Takeaways | Mid-Year Tax Update
THE WAY WE WERE
Investment Management Update – Exit Strategies
Podcast: Introduction to Credit Funds: Basics on How Credit Funds and Private Equity Funds Differ
Episode 26: Talking Tax Reform and Executive Comp
Jeffrey DeBoer on the intersection of Washington and commercial real estate
Welcome to the March 2025 issue of REIT Tax News. Below, we summarize five key developments impacting REITs this past quarter. Carried interest favorable taxation may be in jeopardy - On February 6, 2025, President Donald...more
On February 6, 2025, the Trump Administration announced various tax and budgetary priorities discussed further here, including closing the “carried interest loophole.” On the same day, Democrats in the House and Senate...more
This is The End- I have dreaded the year end for as long as I can remember. As a teenager and then as a young adult I associated the final quarter of the year, and especially the period beginning on Thanksgiving and...more
The Inflation Reduction Act of 2022 (Act), which was signed into law on August 16, is intended to fight inflation and address climate change. The Act provides for over $360 billion in energy- and climate-related investments,...more
On June 27, US Senators Joe Manchin and Chuck Schumer announced proposed legislation referred to as the Inflation Reduction Act of 2022 (the Act). The proposed legislation includes changes that would expand the scope of IRC...more
The U.S. Department of Treasury and the Internal Revenue Service recently issued final regulations (“the Final Regulations”) regarding certain aspects of so-called carried interest under Section 1061 of the Internal Revenue...more
The IRS and Treasury Department released final regulations on January 7, 2021, that govern the tax treatment of partnership and LLC interests related to services, so-called carried interests, a/k/a applicable partnership...more
On January 7, 2021, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations (the “Final Regulations”) providing guidance on Section 1061 of the Internal...more
On January 7, 2021, the Internal Revenue Service (the “IRS”) and the Department of the Treasury released final regulations (the “Final Regulations”) implementing the provisions of Section 1061 of the U.S. Internal Revenue...more
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
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
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
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
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
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
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
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
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
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
New development: The IRS has issued guidance that the exception to the new 3-year hold requirement for carried interests held by “corporations” does not apply to S corporations. As previously discussed, the 2017 Tax Cuts...more
On March 1, the IRS and Treasury announced their intent to issue regulations addressing the new carried interest rules enacted as part of tax reform. More specifically, they intend to clarify that the new rules apply to...more
The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more