Highlights From The Final Carried Interest Regulations

On January 7, 2021, the U.S. Treasury Department and the Internal Revenue Service released final regulations under Section 1061 of the Internal Revenue Code of 1986, as amended (“the Code”). The Final Regulations address the three-year holding period requirement under Section 1061 in order for holders of certain “carried interests” to qualify for preferential capital gains tax rates. The extended holding period requirement was added to the Code in 2017 by H.R. 1, commonly referred to as the “Tax...
By: Goodwin

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