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Section 1061 Final Regulations on the Taxation of Carried Interest  


Author:  Jeremy Naylor.; Amanda Nussbaum.; Scott Jones.; Stephen Severo.


Source: Volume 38, Number 03, Spring 2021 , pp.13-20(8)




Journal of Taxation of Investments

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Abstract: 

The Final Regulations on Section 1061 issued in January 2021 modify the proposed regulations that were released in 2020. These authors highlight certain changes made to the Proposed Regulations, and note other important provisions of the Final Regulations. Taxpayers should find Final Regulations generally helpful, however, some questions remain unresolved, so fund managers will need to continue to exercise care in interpreting and applying the Final Regulations.

Keywords: carried interest, carry waivers, T.D. 9945, IRC Sec. 1061, capital interest exception

Affiliations:  1: Proskauer Rose LLP; 2: Proskauer; 3: Proskauer; 4: Proskauer.

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