Carried Interests: Tax

Summary

This practice note analyzes the impact of I.R.C. Section 1061, which was created by the Tax Cuts and Jobs Act of 2017 (TCJA), Pub L No 115-97, and how it alters the character of some income recognized with respect to certain types of partnership interests. The practice note describes the operative provision of I.R.C. Section 1061 and its modified definition of long-term gain with respect to certain types of partnership interests in extending the required holding period of capital assets from one to three years.