IRS Carried Interest Guidance under I.R.C. Section 1061

Summary

This practice note discusses the carried interest rules under I.R.C. Section 1061, and its application to private investment funds and their U.S.-based managers. This practice note assumes that all managers are U.S. persons taxable in the U.S. and that all investments are made in the U.S. Except as otherwise indicated, this summary only discusses U.S. federal income tax rules and does not address any state, local, foreign or non-income tax rules.