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Proposed Regulation Partnership Interests Internal Revenue Code (IRC)

Holland & Knight LLP

Proposed Rule Modifies Timing of "Hot Asset" Reporting

Holland & Knight LLP on

Generally, gain or loss on the sale or exchange of a partnership interest is treated as capital gain or loss except to the extent of so-called "hot assets." Gain attributable to hot assets – generally unrealized receivables...more

Eversheds Sutherland (US) LLP

Inflation Reduction Act targets carried interests

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

Goodwin

Highlights From The Proposed Carried Interest Regulations

Goodwin on

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

Proskauer Rose LLP

Key Takeaways from the Proposed Regulations on Carried Interest

Proskauer Rose LLP on

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

Latham & Watkins LLP

IRS Issues Proposed Regulations Addressing Management Fee Waivers

Latham & Watkins LLP on

Certain arrangements would be recharacterized as ordinary income, rather than as distributive shares of partnership income. On July 22, 2015, the US Treasury Department and the US Internal Revenue Service (IRS) released...more

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