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Tax Cuts and Jobs Act Carried Interest

Paul Hastings LLP

One Big Beautiful Bill Act — A Private Equity Perspective

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On July 4, President Donald Trump signed into law the One Big Beautiful Bill Act (OBBBA). This alert summarizes the key changes under the OBBBA relevant to private equity sponsors and their investors, as well as some of the...more

Ropes & Gray LLP

2025 Tax Legislation Update: One Big Beautiful Bill Act Narrowly Passes Senate

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The “One Big Beautiful Bill Act” (the “BBB”) was passed by the U.S. House of Representatives on May 22, 2025 (such version, the “House Bill”) as part of the Republican Congress’s reconciliation package. The BBB generally...more

Ropes & Gray LLP

2025 Tax Legislation Update

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On May 22, 2025, the U.S. House of Representatives passed the “One Big Beautiful Bill Act” (the “BBB”) as part of the Republican Congress’s reconciliation package. The BBB generally extends certain tax provisions of the 2017...more

Akin Gump Strauss Hauer & Feld LLP

2025 Perspectives in Private Equity: Tax Analysis

Major portions of the U.S. tax code are scheduled to expire at the end of 2025, and as the U.S. tax landscape faces potential upheaval, private equity firms must stay vigilant and adaptable. Proactively engaging with tax...more

DLA Piper

REIT Tax News - March 2025

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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

Cadwalader, Wickersham & Taft LLP

Tax Proposals Bid Adieu to Carried Interest

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

Cadwalader, Wickersham & Taft LLP

Shrinking Carried Interest Loophole Under Attack Again

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

Rivkin Radler LLP

Taxes and the 2024 Election: ‘Tis the Season to Plan and Act

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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

Davies Ward Phillips & Vineberg LLP

U.S. Climate Change and Healthcare Bill Moves Democrats’ Tax Policy Forward

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

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

Rivkin Radler LLP

The Schumer-Manchin Proposal To “Eliminate” the Profits Interest

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Summer Break? After the last couple of weeks, I’m looking forward to Congress’s summer vacation. I’m pretty sure our elected representatives feel the same way, though it is unclear at this point when they will be heading...more

Freeman Law

Hedge Funds 101: An Introduction to Tax Issues

Freeman Law on

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

ArentFox Schiff

“Should Five Percent Appear Too Small, Be Thankful I Don’t Take It All”: Ways and Means Committee Advances Tax Increase and Reform...

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The House Ways and Means Committee advanced key tax reform proposals on September 15 that would increase taxes for corporations and high-income individuals. Several tax reform proposals are under consideration as part of...more

Williams Mullen

IRS Releases Finalized Regulations Regarding Taxation of Carried Interest

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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

Gould + Ratner LLP

IRS Finalizes Carried Interest Regulations

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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

Proskauer - Tax Talks

Section 1061 Final Regulations on the Taxation of Carried Interest

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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

Mintz - Real Estate, Construction &...

IRS Issues Final Regulations on Taxation of Carried Interest Under Section 1061

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

Jones Day

U.S. Treasury Department Releases Proposed Carried Interest Regulations

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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

Neal, Gerber & Eisenberg LLP

Fund Managers and Family Offices Get Some Clarity on Carried Interests with Issuance of Proposed Treasury Regulations

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

McDermott Will & Schulte

IRS Issues Proposed Regulations Intended to Clarify Carried Interest Rules

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

Herbert Smith Freehills Kramer

Long-Awaited Treasury Regulations Address the Application of Section 1061 to Carried Interests

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

Ballard Spahr LLP

Carried Interest – Proposed Regulations and the Impact on Private Equity

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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

Troutman Pepper Locke

Proposed Regulations Shed Light on Three-Year Holding Period Requirement for Carried Interest

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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

Ballard Spahr LLP

Carried Interest – Proposed Regulations – Impact on Real Estate: The Good and the Bad

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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

White & Case LLP

Overview of the Carried Interest Rules and the Proposed Regulations

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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

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