New Holding Period Requirement and Other New Issues and Opportunities
Major changes to carried interest rules were made under TCJA, but only clarified in the IRS final regulations last year. And still areas of uncertainty are making it difficult to provide cogent advice to business clients. Clarify what partnership interests are subject to the new rules, who's affected, what the exceptions are, and how to plan around it. Register today!
Determine which clients are most affected by the new rules and how their tax reporting must change.
Clarify how to identify interests subject to IRC 1061.
Learn how the new three-year holding period requirement can be circumvented.
Identify new avenues of ensuring favorable tax treatment.
Carried Interest Tax Rules Changes Under the TCJA
IRS Section 1061 Final Regulations (Jan 2021) and Effective Dates
IRC 1061 and 1231 Current Gray Areas, Case Studies, Planning Opportunities
Joseph C Mandarino is an attorney with the law firm of Smith, Gambrell & Russell, LLP. His practice focuses primarily on tax and financial planning. Mr. Mandarino writes and speaks on a of business, tax and finance topics. He has published over 100 articles in journals and in-house newsletters, and has participated in over 200 presentations and seminars. His articles have appeared in the National Law Journal, Mergers & Acquisitions magazine, Tax Notes Today, the Journal of Real Estate Taxation, the Journal of S Corporation Taxation, the Journal of Multistate Taxation, the Tax & Finance Newsletter and the NYU Institute on Federal Taxation. In addition, Mr. Mandarino has spoken at meetings and seminars organized by numerous organizations, including the American Bar Association, the White House Conference on Small Businesses, the U.S. Small Business Administration, the Georgia Electronic Commerce Association, the Federation of Exchange Accommodators, the International Reinsurance Conference, the Service Corps of Retired Executives and the United Way, as well as several panel-type TV discussion programs. He earned his B.A. degree from the University of Toronto; his J.D. degree, cum laude, from Loyola University School of Law; and his LL.M. degree from New York University School of Law.
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