Co-Investment Vehicles Under the Final Carried Interest Regulations
By EsqSocial Corporation 21/06/21
As a result of final Treasury Regulations issued by the IRS under Section 1061, fund sponsors should consider investing capital through a commingled fund with other investors as opposed to using its own investment vehicle to invest in parallel with the fund, which could be subject to the three-year holding period requirement under Section 1061. Section 1061 recharacterizes certain net long-term capital gain with a holding period of less than three years as short-term capital gain at ordinary...
By: Foley & Lardner LLP