IRS Issues Final Regulations on Partnership Carried Interests | Locke Lord LLP
On January 13, 2021, the Internal Revenue Service (“ IRS”) and the U.S. Treasury Department (“ Treasury”) issued the official version of Final Treasury Regulations (the “ Final Regulations”) providing guidance under the “carried interest” rules of Section 1061 of the Internal Revenue Code of 1986, as amended (the “ Code”). 1 The Final Regulations address a number of previously open questions regarding the scope and implementation of Section 1061 which was enacted as a part of the 2017 Tax Cuts and Jobs Act. The Final Regulations in large part adopt the Proposed Treasury ...