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To print this article, all you need is to be registered or login on Mondaq.com. Asset managers should be aware that on January 7, 2021, the IRS released final regulations (the Final Regulations ) implementing section 1061 of the Code, which governs the character of carried interest gains allocated to or derived by a service partner in an investment fund. Very generally, the statute denies access to the 20% rate for long-term capital gains attributable to a carried interest unless the holder of the asset has a holding period of more than three years. Capital gains for which long-term treatment is denied will be ....