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- Title
The "Carried Interest" Rules of Section 1061: Proposed Regulations Resolve Several Ambiguities Under the Statute.
- Authors
Creamer Jr., Ronald E.; Feldman, Zachary W.; Motten, Andrew B.; Spitzer, David C.; Wang, Davis J.; Wheeler, Isaac
- Abstract
The recently released proposed regulations under Code Section 1061 are a mixed bag for taxpayers. Certain aspects of Section 1061 are interpreted narrowly, but the proposed regulations are broad in other respects. And the proposed regulations provide detailed--and in some cases very complex--rules on how taxpayers should calculate the amount of long-term capital gain recharacterized as short-term capital gain under Section 1061 and the application of certain exceptions. Affected taxpayers, particularly hedge funds and private equity industries, and their advisors should closely review the proposed regulations.
- Subjects
CAPITAL gains; PRIVATE equity funds; HEDGE funds; STATUTES; AMBIGUITY
- Publication
Journal of Taxation of Investments, 2020, Vol 38, Issue 1, p35
- ISSN
0747-9115
- Publication type
Article