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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 rules generally are taxpayer-favorable, they are not without uncertainty.
Background
A carried interest is an interest in partnership profits that is transferred to a service provider, such as a fund manager, in exchange for investment- and management-related services. Section 1061 extends the applicable long-term capital gain holding period for an “applicable partnership interest” (API)
United States: How do you spell relief? C-A-A
After months of partisan bickering and Senate inaction, Congress finally passed another round of COVID-19 relief legislation as part of the Consolidated Appropriations Act, 2021, P.L. 116-260, (“CAA”), which was signed into law on December 27, 2020. We provide a summary of the tax-related CAA provisions and key modifications to the Paycheck Protection Program (“PPP”), before discussing President Biden’s tax agenda for 2021. The CAA’s tax provisions focus primarily on providing economic relief to taxpayers by expanding provisions of the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) and renewing extenders. -
In brief