Treatment of carried interest: Breaking down the proposed regulations

With the recent release of long-awaited proposed regulations, the Treasury Department and IRS have clarified many uncertainties pertaining to the treatment of “carried interest” under Internal Revenue Code (IRC) Section 1061, which increases the required holding period to greater than three years for fund managers who benefit from the lower long-term capital gains rate on an “applicable partnership interest” (API). However, many questions remain unclear. 

In a newly published article for Bloomberg Tax, CohnReznick’s Moshe Biderman, Jonathan R. Collett, and Robert Richardt discuss what is and is not subject to Section 1061 under the proposed regulations, as well as what fund managers should do now.

Read their article at BloombergTax.com, or download the PDF below.

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