Proposed Carried Interest Regulations: Treasury Carries the Ball, Giving Precious Few Points to Fund Managers
August 11, 2020
The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) on July 31, 2020 issued long-awaited proposed regulations (the “Proposed Regulations”) providing guidance under section 1061 of the U.S. Internal Revenue Code of 1986, as amended (the “Code”). Section 1061, which was added to the Code as part of the Tax Cuts and Job Act of 2017, addresses the tax treatment by recipients of “carried interests” and “performance allocations” with respect to taxable years beginning after 2017.
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