Statute
Internal Revenue Code Section 1061
3 published works
Tax Talks
Section 1061 Final Regulations on the Taxation of Carried Interest
By Jeremy Naylor, Amanda H. Nussbaum, Scott S. Jones, David S. Miller, Stephen Severo, Brianna Reed, Kaitlyn L. Flynn-Rozanski
On January 7, 2021, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations[1] (the “Final Regulations”) providing guidance on Section 1061…
Legacy Advisors
3-Year Holding Period Rule for ‘Carried Interests’ Addressed in IRS Proposed Regulations
By James A. Martin, Niya Tang, Erez I. Tucner, Jennifer H. Weiss
On July 31, 2020, the Department of Treasury and IRS issued proposed regulations that provide guidance to the “carried interest” rules under Section 1061 of the Internal Revenue Code. Long-term…
The CLS Blue Sky Blog
Davis Polk Discusses IRS Proposal on Carried Interest Regulations
By David Schnabel, Patrick Sigmon, Ethan Goldman
On July 31, the IRS and Treasury proposed regulations (the “Carried Interest Regulations”) on the taxation of carried interest under Section 1061 of the tax code. Section 1061 was added…