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Action Items for Investment, Private Equity, Real Estate Fund Managers

Investment, private equity, real estate fund managers should become familiar with complex final regulations on preferential tax treatment of carried interest under Section 1061 of Internal Revenue Code generally effective for taxable years beginning on or after Jan. 1, 2022.
Donald Trump Treasury Department Holding Rule Internal Revenue Code Fund Manager Investment Pass Through Entity

Section 1061 Final Regs on the Taxation of Carried Interest

Friday, January 15, 2021 On January 7, 2021, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations [1] (the “Final Regulations”) providing guidance on Section 1061 of the Internal Revenue Code (the “Code”). [2] The Final Regulations modify the proposed regulations [3] (the “Proposed Regulations”) that were released in July of 2020. We previously discussed the Proposed Regulations with a seri...
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