11Aug
IRS clarifies holding period rules for profits interests and carried interests
The Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) that govern the tax treatment of certain equity interest under Section 1061 of the Internal Revenue Code of 1986, as amended (the “Code”). Specifically, the Proposed Regulations clarify certain applications of the three-year holding period rules and, as a result, taxpayers may need to reconsider certain aspects of profits interests and carried interests awards....
By:
Thompson Coburn LLP
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