The "carried interest" rules of Section 1061 proposed regulations resolve several ambiguities under the statut Ronald E. Creamer, Zachary W. Feldman, Andrew B. Motten, David C. Spitzer, Davis J. Wang, and Isaac Wheeler
Contributor(s): Creamer, Ronald E
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Material type: 
ArticlePublisher: 2020Subject(s): RENDIMIENTOS DE CAPITAL | PLUSVALIAS | INTERES | IMPUESTOS | ESTADOS UNIDOSOnline resources: Click here to access online
In:
Journal of Taxation of Investments v. 38, n. 1, Fall 2020, p. 35-48Summary: The recently released proposed regulations under Code Section 1061 are a mixed bag for taxpayers. Certain aspects of Section 1061 are interpreted narrowly, but the proposed regulations are broad in other respects. And the proposed regulations provide detailed—and in some cases very complex—rules on how taxpayers should calculate the amount of long-term capital gain recharacterized as short-term capital gain under Section 1061 and the application of certain exceptions. Affected taxpayers, particularly hedge funds and private equity industries, and their advisors should closely review the proposed regulations.
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Disponible también en formato electrónico.
Resumen.
The recently released proposed regulations under Code Section 1061 are a mixed bag for taxpayers. Certain aspects of Section 1061 are interpreted narrowly, but the proposed regulations are broad in other respects. And the proposed regulations provide detailed—and in some cases very complex—rules on how taxpayers should calculate the amount of long-term capital gain recharacterized as short-term capital gain under Section 1061 and the application of certain exceptions. Affected taxpayers, particularly hedge funds and private equity industries, and their advisors should closely review the proposed regulations.
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