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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Any advice contained in this communication, including attachments and enclosures, is not intended as a thorough, in-depth analysis of specific issues. Nor is it sufficient to avoid tax-related penalties. This has been prepared for information purposes and general guidance only and does not constitute legal or professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice specific to, among other things, your individual facts, circumstances and jurisdiction. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and CohnReznick LLP, its partners, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.