The U.S. Treasury Department ("Treasury") and the Internal Revenue Service will provide guidance for taxpayers on how the new limits to the carried interest provisions under the Tax Cuts and Jobs Act will be implemented. The notice announces, among other things, that the Treasury and the IRS intend that new regulations will provide that the definition of the term "corporation," will not include an "S corporation" for purposes of IRC Section 1061(c)(4)(A).
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