Hot Topics: Sec. 163(j) & Sec. 1061 for Hedge Funds

Webcast overview

Join KPMG for our Hot Topics in Tax: Section 163(j) and Section 1061 for Hedge Funds webcast. This webcast features leading KPMG tax professionals who address the new final and proposed regulations under Section163(j) and the new proposed regulations under section 1061 and their implications for hedge funds. Specific topics include:

  • Section 163(j) – Interest Expense Limitations:
    • Material participation for trader funds
    • Changes to the definition of interest and hedging rules
    • RIC dividends as interest income
    • Here to stay…the 11-step process
    • Tiering through partnerships
    • Releasing prior 163(j) limitations applied to limited partners
    • Debt financed distributions and interest expense tracing for GP members
    • Utilizing the small business exception
  • Section 1061 – “Carried Interest” Proposed Regulations:
    • Capital Accounts versus API
    • Earnings on realized and unrealized appreciation
    • Section 1256, Section 1231, and QDI
    • Transfers to partners, feeder funds, and related parties
    • Carry waivers
    • Seeder shares
    • New reporting rules


  • Jay Freedman, Global and National Hedge Fund Tax Segment Leader
  • Anthony Tuths, Principal, Tax, Asset Management
  • Charles Kaufman, Managing Director, Tax, Washington National Tax
  • Matthew Busta, Managing Director, Tax, Washington National Tax