Private Funds Nuts and Bolts: Proposed Carried Interest Regulations: Treasury Carries the Ball, Giving Precious Few Points to Fund Managers

On July 31, 2020, U.S. Department of the Treasury and the U.S. Internal Revenue Service issued long-awaited proposed regulations (the "Proposed Regulations") providing guidance under section 1061 of the U.S. Internal Revenue Code. Section 1061, which was enacted as part of the Tax Cuts and Jobs Act of 2017, addresses the tax treatment by recipients of "carried interest" and "performance allocations" with respect to taxable years beginning after 2017. Our webinar will provide an overview of the Proposed Regulations and discuss their potential implications for alternative fund managers and other recipients of carried interest and performance allocations.