ARTICLE
21 August 2020

Proposed Regulations Addressing Three-Year Carried Interest Rules: What You Need To Know To Preserve Long-Term Capital Gain Treatment

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A&O Shearman

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A&O Shearman was formed in 2024 via the merger of two historic firms, Allen & Overy and Shearman & Sterling. With nearly 4,000 lawyers globally, we are equally fluent in English law, U.S. law and the laws of the world’s most dynamic markets. This combination creates a new kind of law firm, one built to achieve unparalleled outcomes for our clients on their most complex, multijurisdictional matters – everywhere in the world. A firm that advises at the forefront of the forces changing the current of global business and that is unrivalled in its global strength. Our clients benefit from the collective experience of teams who work with many of the world’s most influential companies and institutions, and have a history of precedent-setting innovations. Together our lawyers advise more than a third of NYSE-listed businesses, a fifth of the NASDAQ and a notable proportion of the London Stock Exchange, the Euronext, Euronext Paris and the Tokyo and Hong Kong Stock Exchanges.
Partner Todd Lowther, Derek Kershaw and associate Matthew Behrens will discussed the Internal Revenue Service's proposed regulations providing guidance under Section 1061 of the Internal Revenue Code.
United States Tax

Webcast

Partner Todd Lowther, Derek Kershaw and associate Matthew Behrens will discussed the Internal Revenue Service's proposed regulations providing guidance under Section 1061 of the Internal Revenue Code. The presentation covered some key points and examples relating to the proposed regulations, including guidance for determining the amount of gain to be recharacterized pursuant to Section 1061, certain relevant exceptions as well as new reporting requirements for affected partnerships. Tax Team Leader Michael Shulman moderated the discussion.

Originally published 21 August, 2020

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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