Selected US Tax Developments: New Proposed Regulations Under the Section 1061 Carried Interest Rules | Zendy

Peter A. Glicklich | Zendy; Gregg M. Benson | Zendy

AI Assistant Blog Pricing

Home ZAIA Blog

Open Access

Selected US Tax Developments: New Proposed Regulations Under the Section 1061 Carried Interest Rules

Author(s) -

Peter A. Glicklich,

Gregg M. Benson

Publication year - 2021

Publication title -

canadian tax journal/revue fiscale canadienne

Language(s) - English

Resource type - Journals

ISSN - 0008-5111

DOI - 10.32721/ctj.2020.68.4.ustd

Subject(s) - internal revenue , section (typography) , business , service (business) , revenue , key (lock) , capital (architecture) , code (set theory) , finance , computer science , computer security , marketing , advertising , archaeology , set (abstract data type) , history , programming language

The Tax Cuts and Jobs Act of 2017 added new section 1061 to the Internal Revenue Code. That provision added a three-year holding period for fund managers holding "carried interests" to qualify for long-term capital gain treatment. On August 14, 2020, the Internal Revenue Service published proposed regulations that provide much-needed guidance. As proposed, however, the new rules are quite complex and include a number of traps for the unwary. We discuss some of the key provisions of the proposed regulations and consider their impact for Canadian funds and their Canadian and US managers.

The content you want is available to Zendy users.

Already have an account? Click here to sign in.

Having issues? You can contact us here

Accelerating Research