Carried Interest: A Discussion of the Recent Proposed Regulations under Section 1061

Section 1061 was added to the Internal Revenue Code as a result of the Tax Cuts and Jobs Act (TCJA).  In general, section 1061 was enacted to address the tax treatment of certain compensatory partnership interests (or “carried interests”) by converting net long-term capital gains with respect to such interests into short-term capital gains taxed as ordinary income. However, the new provision created many uncertainties.

On July 31, 2020, the U.S. Treasury Department and the IRS published proposed regulations under section 1061 (the Proposed Regulations). KPMG LLP (KPMG) is pleased to invite you to a 90-minute webcast that discusses the Proposed Regulations. Senior-level KPMG Passthroughs professionals from KPMG’s Washington National Tax provide:

• A high-level overview of section 1061
• A more detailed discussion of the Proposed Regulations
• Analysis of how old issues have been addressed, which issues are still unresolved, and what new issues have been created
• Thoughts along the way for planning and structuring considerations for taxpayers that conduct business through entities classified as partnerships for federal tax purposes.