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.
Day Pitney Generations Newsletter
Day Pitney Generations Newsletter
Day Pitney Generations Newsletter
Day Pitney Generations Newsletter
Day Pitney Generations Newsletter
Day Pitney Generations Newsletter
In October 2023, Day Pitney represented a state pension system client in connection with a $200 million investment in a $20 billion private equity fund, and its accompanying co-investment vehicle, focused on acquiring, operating and disposing of financing, software, data and technology-enabled businesses.
Three Boston-based Private Client Department Day Pitney Partners were selected for inclusion on Boston magazine's Top Lawyers of 2023 List*. The selected attorneys are: Jordana G. Schreiber, Partner – Trusts and Estates; David L. Silvian, Partner – Trusts and Estates; and Christine N. Fletcher, Partner – Trusts and Estates.
Day Pitney Trusts and Estates Attorney Nikolaus Schuttauf was featured in The Wall Street Journal article titled, "The Estate Tax Catching Americans by Surprise."
Day Pitney Trusts and Estate Attorney G. Warren Whitaker authored the article, "The Dog Ate My Kids' Inheritance: Providing for Pets in an Estate Plan," for New Jersey Lawyer.
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