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The Inflation Reduction Act Would Further Increase Holding Periods for Long-Term Capital Gain Eligibility for Carried Interest

USA - July 29 2022 On July 27, 2022, Senate Majority Leader Chuck Schumer (D-NY) and Senator Joe Manchin (D-WV) announced an agreement on a climate, health and tax…

Alex Farr, Andrew M Granek, Alejandro Ruiz, Kwabena A. Yeboah

Tax Reform Insights: IRS Proposes Section 163(j) Regulations - New Business Interest Expenses Deduction Limit

USA - December 26 2018 On November 26, 2018, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) pursuant to section 163(j). Public Law…

Emily Mussio, David Sherwood

Section 1202 Post-TCJA

USA - May 22 2018 Changes made by tax reform have caused companies to reevaluate their structures. This reevaluation extends to the most fundamental decision: choice of…

Michael J. Wilder, Daniel N. Zucker

IRS Issues Proposed Regulations Intended to Clarify Carried Interest Rules

USA - August 24 2020 The Internal Revenue Service (IRS) recently issued proposed regulations under section 1061, a provision enacted as part of the Tax Cuts and JOBS Act…

Patrick J. McCurry, Alejandro Ruiz, Thomas P. Ward, Gregory M. Weigand

IRS Publishes Proposed Section 199A Regulations

USA - August 24 2018 The IRS recently issued proposed regulations under Section 199A, a provision enacted as part of tax reform to allow individuals and certain other…

Patrick J. McCurry, Alejandro Ruiz, Thomas P. Ward