Proposed Regulations on Carried Interests

by Augusto Egoavil

On July 31, 2020, the IRS issued proposed regulations ([REG-107213-18]) under Section 1061 of the Internal Revenue Code (the “Code”) as required by Code Section 1061(f). The proposed regulations provide guidance on the application of Code Section 1061, and also include new regulations regarding the treatment of carried interests held by the partnership sponsor or through one or more tiered pass-through vehicles. Also, the proposed regulations contain new reporting rules.