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Saturday, January 30, 2021 On January 6, 2021, the IRS issued T.D. 9944 (the “Final Regulations”), which finalizes the proposed regulations under section 45Q (the “Proposed Regulations”) that were issued in REG-112339-19 on May 28, 2020 and discussed in an earlier post. This article summarizes the key ways in which the Final Regulations differ from their predecessor. Broadly Applicable Concepts The Final Regulations, as with the Proposed Regulations, contain numerous concepts that are roughly transposed, with some innovations, from the section 45 production tax credit (“P...

To embed, copy and paste the code into your website or blog: 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”). [1] 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 Cuts and Jobs Act.” T...

To embed, copy and paste the code into your website or blog: On December 18, 2020, the Internal Revenue Service (“IRS”) and Treasury Department released final regulations (the “Final Regulations”) interpreting the Tax Cuts and Jobs Act’s (the “Act’s”) revisions to Section 162(m) of the Internal Revenue Code (the “Code”), which limits a publicly held corporation’s deductions for compensation paid to “covered employees” in excess of $1 million. The Final Regulations arrive one year after the proposed regulations published on December 20, 2019 (the “Proposed Regulatio...

Thursday, January 28, 2021 On January 6, 2021, the Department of the Treasury and the Internal Revenue Service (IRS) issued final regulations (the Final Regulations) under section 45Q of the Internal Revenue Code of 1986, as amended (Section 45Q), which allows a credit for carbon oxide sequestration (the Section 45Q Credit). The Final Regulations amend and clarify the proposed regulations under Section 45Q (the Proposed Regulations) released on May 28, 2020, described in Bracewell’s alert available here.  In 2020, the IRS also issued Notice 2020-12 (the Notice), providing ...

To embed, copy and paste the code into your website or blog: While the final regulations simplify key exceptions and contain favorable changes, ambiguity continues for investment fund managers. On January 7, 2021, the US Treasury Department and Internal Revenue Service (together, Treasury) published final carried interest regulations (the Final Regulations) under Section 1061,1 which is intended to limit long-term capital gain treatment attributable to “carried interest” arrangements issued to owners and employees of private fund sponsors by imposing a three-year holding period requireme...