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Senior Associate Justin M. Hannan and Partner Stephen Ziobrowski were quoted in the Law360 Tax Authority article, "Carried Interest Regs Leave Uncertainty On Family Managers." The article is an in-depth discussion on how the statute on carried interest excludes family office gains from a three-year holding period for capital gains treatment, and how the IRS did not address the exception in regulations, leaving uncertainty about interest paid to the financial managers of high-net-worth families.
Hannan stated, "What makes [Section] 1061 so important is the fact that your capital gain could be taxed at ordinary income rates – that's why it matters. But the new administration might increase capital gains rates to be at the same as ordinary income."
"Do they have to track the holding period of the assets like a big private equity or hedge fund that has a prospectus and is marketed by brokers, or do they qualify for this exception under 1061(b)? I think you can make the argument either way, but it's unclear," added Ziobrowski.
Read full article here.
Daniela P. Catrocho and Richard D. Sanders authored the article, "Retroactive Tax Legislation and Gift Planning in 2021," which was published in the New Jersey Law Journal.
On February 24, Partner Carl A. Merino spoke on "Reporting by U.S. Person of Foreign Income, Assets and Transactions" at a webinar hosted by STEP Colorado Formation and STEP Chicago.
The ABA recently published the 25th Edition of The Property Tax Deskbook.
Day Pitney Press Release
Day Pitney Press Release
Day Pitney Press Release
On March 11, Day Pitney Counsel Jordana G. Schreiber spoke on the "Basics of Estate Planning" for physicians at Massachusetts General Hospital.
Daniela P. Catrocho and Richard D. Sanders authored the article, "Retroactive Tax Legislation and Gift Planning in 2021," which was published in the New Jersey Law Journal.
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