Carried Interest Update: Final Regulations Provide Taxpayer-Favorable Rules, but Unanswered Questions Linger | BakerHostetler
To embed, copy and paste the code into your website or blog: On Jan. 19, 2021, the Internal Revenue Service and the Treasury Department published final regulations on the Section 1061 “carried interest” rules (T.D. 9945). The final regulations generally adopt proposed regulations issued in July 2020 (please see our alert from Aug. 18, 2020) but make significant changes to (i) the exception for capital interests, (ii) the look-through rule that applies to certain dispositions of partnership interests and (iii) the rule for non-recognition transfers to certain related persons. While the new...