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Carried Interest Changes in the Inflation Reduction Act of 2022

USA - July 29 2022 On July 27, 2022, U.S. Senate Majority Leader Chuck Schumer, D-N.Y., and Sen. Joe Manchin, D-W.Va., announced an agreement to add the Inflation…

Scott Pollock, Noam M. Waltuch

IRS Releases Final Regulations on Recharacterization of Carried Interest

USA - January 11 2021 On January 7, 2021, the U.S. Internal Revenue Service (IRS) and Department of the Treasury released final regulations (Final Regulations) applicable…

Dominique Gallego, Christian D. Molander-Barraza, Scott Pollock, Jennifer Waclawik, Noam M. Waltuch

IRS Releases Proposed Regulations on Recharacterization of Carried Interest

USA - August 7 2020 On July 31, 2020, the U.S. Internal Revenue Service (IRS) released proposed regulations (Proposed Regulations) applicable to the carried interest…

Dominique Gallego, Christian D. Molander-Barraza

Proposed Regulations Under U.S. Internal Revenue Code Section 199A

USA - August 20 2018 On Aug. 8, the United States Internal Revenue Service (IRS) and Department of the Treasury released proposed regulations (the Proposed Regulations) on…

Laura M. Barzilai, Dominique Gallego, Jonathan M. Westreich

IRS Issues Interim Partial Relief From the Withholding Tax Obligations on Transfers of Partnership Interests

USA - April 3 2018 On April 2, 2018, the Internal Revenue Service (IRS) issued Notice 2018-29 (Notice), providing important interim partial relief from the withholding…

Daniel Altman, Dominique Gallego, Ivy H. Jones, Angela T. Richards