IRS Issues Final Carry Regulations - Finance and Banking
On January 7, 2021 Treasury and the IRS released final regulations (the " Final Regulations") on the "three-year carry rule" enacted in 2017 pursuant to Section 1061. 1 The Final Regulations largely retain the rules proposed on July 31, 2020 (the " Proposed Regulations") but with some material, mostly taxpayer-favorable, modifications. The Final Regulations are generally effective for tax years beginning after their publication on January 19, 2021, 2 giving partnerships with December tax year-ends the balance of 2021 to prepare for their application. Generally, the Final Regulations, like th...