The Sec. 1061 capital interest exception and its impact on hedge funds

Sec. 1061's application is generally limited to a profits interest in hedge funds, private-equity and venture-capital funds, real estate funds, or other ...

Final IRC Section 1061 carried interest regulations have ...

The capital interest exception, including the treatment of (a) capital interests acquired with certain loan proceeds and (b) the treatment of ...

Section 1061 Final Regulations on the Taxation of Carried Interest

In general, Section 1061 requires a three-year holding period for an investment fund manager's share of capital gains earned through a fund to ...

Dealing With Section 1061's Three Year Holding Period ...

Generally, Section 1061 pulls within its scope many investment partnerships, but will impact hedge funds more often than PE funds given the ...

IRS Finalizes Carried Interest Regulations - Brass Tax

Section 1061 imposes a three-year holding period as a precondition to recognizing long-term capital gains on carried interests issued to investment ...

Final Carried Interest Regulations: Key Takeaways for Private Fund ...

Notably, the capital interest exception applies to the sponsor's capital investment even if the investment is ... their invested capital ...

3-Year Holding Period Rule for 'Carried Interests' Addressed in IRS ...

An applicable partnership interest (i.e., a “carried interest”) does not include for purposes of Section 1061 (i) a partnership interest held by ...

Final regulations on tax treatment of carried interest | Global law firm

Capital gain of a fund manager that is subject to Section 1061, where the holding period is three years or less, is treated as short term capital gain subject ...

Carried Interest Rules: Final Section 1061 Regulations Are Now in ...

As a result, most private equity, venture capital, real estate, and hedge funds are now subject to Section 1061. Exceptions to the New ...

Guidance Under Section 1061 - Federal Register

Section 1.1061-3 provides guidance on the exceptions to the definition of an API, including the capital interest exception. Section 1.1061-4 ...

Key implications of the IRC Section 1061 carried interest proposed ...

Where it applies, IRC Section 1061 recharacterizes gains arising from the sale of capital assets held for one to three years, otherwise eligible ...

Carried Interest: The New Frontier for Investment Professionals

Capital Asset is not exempt from the application of section 1061. P has held its API in GP for more than three years, GP has held its interest in Fund for more ...

Sec. 1061 Partnership interests held in connection with performance ...

IRC section 1061 provides for the treatment of so-called carried interests, which are profits interests in partnerships received for the performance of ...

IRS Issues Final Regulations on Carried Interest

such relief—in its view, because the Capital Interest Exception ... the hedge fund manager's capital interest as well as private equity funds with.

Final 1061 Regulations - Weil Tax BLOG

... Section 1061 (the “Capital Interest Exception”). The Final ... Capital Interest Exception for existing Funds. The Final Regulations ...

IRS Final-Carried Interest Regulations More Favorable to Fund ...

Section 1061 defines as an API a partnership interest held by, or transferred to, a taxpayer, directly or indirectly, in connection with the ...

Carried Interest Regulations and the Future of a Debated Tax Break

An interest that is subject to Section 1061 — and thus subject to recharacterization as short-term capital gain — is called an “applicable ...

IRS Issues Final Regulations on Carried Interests - Morgan Lewis

Section 1061 provided that a taxpayer (other than a corporation) receiving a carried interest that was an applicable partnership interest (API) ...

Section 1061 Reporting guidance FAQs | Internal Revenue Service

... capital gain allocated with respect to any applicable partnership interest (API) to be treated as long-term capital gain.

Final Regulations Issued on Treatment of Carried Interests

IRC Sec. 1061 recharacterizes certain net long-term capital gains of a partner that holds one or more applicable partnership interests (“APIs,” ...