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26 U. S. Code § 1061 - LII Legal Information Institute To the extent provided by the Secretary, subsection (a) shall not apply to income or gain attributable to any asset not held for portfolio investment on behalf of third party investors
Section 1061 Reporting guidance FAQs - Internal Revenue Service For taxable years beginning after December 31, 2017, section 1061 recharacterizes certain net long-term capital gains of a partner that holds one or more applicable partnership interests as short-term capital gains
Final IRC Section 1061 carried interest regulations have . . . - EY IRC Section 1061, enacted by the Tax Cuts and Jobs Act of 2017, generally requires certain carried interest arrangements to be held for more than three years for the related capital gains to qualify for tax-favored long-term capital gain (LTCG) treatment
IRC 1061: Tax Changes Fund Managers Need to Know | Weaver This section aims to limit the favorable tax treatment that fund managers benefitted from on their carried interest Specifically, gains from these interests are treated as short-term capital gains unless the underlying partnership assets have been held for more than three years