Under current (post-2017) federal income tax law, long-term capital gain allocated to or realized by a non-corporate recipient of a promote or other performance-based allocation (a "Carried Interest") in the investment management industry generally is recharacterized as short-term capital gain and therefore is not eligible for a reduced federal income tax rate if the gain results from a sale of an asset held for three years or less.
The Proposed Regulations under Section 1061 issued on July 31 (the "Carried Interest Regulations") (REG-107213-18) address some of these issues. The Carried Interest Regulations generally are not effective until taxable years beginning on or after the date on which the final regulations are published (except for certain provisions noted below), and are likely to be revised before they are finalized.
Other things to check out:
The SECURE Act and Your Retirement Savings - TAPinto
The Setting Every Community Up for Retirement Enhancement (SECURE) Act was enacted in December 2019 as part of a larger federal spending package. This long-awaited legislation expands savings opportunities for workers and includes new requirements and incentives for employers that provide retirement benefits. At the same time, it restricts a popular estate planning strategy for individuals with significant assets in IRAs and employer-sponsored retirement plans.
Here are some of the changes that may affect your retirement, tax, and estate planning strategies. All of these provisions were effective January 1, 2020, unless otherwise noted.
IRS PLR: Foundation's Proposed Grants to Public Entities Consistent With Tax-Exempt Purpose (IRC
Conservative Carbon Tax: Bad Politics, Bad Policy | Competitive Enterprise Institute
Conservatives are pro-growth; hence, pro-energy and anti-tax. Progressives are anti-growth, hence, pro-tax and anti-energy. Touting carbon taxes would blur a basic distinction that is a critical political asset for conservatives.
Most current proposals feature "fee-and-dividend" programs and suspend certain Clean Air Act (CAA) regulations. However, no enacted carbon tax would be "revenue neutral," and even if it were, the tax would still be economically harmful. Nor would a carbon tax be deregulatory. Indeed, carbon pricing would expand federal regulation due to its inevitable pairing with a system of border taxes.
Not to change the topic here:
Long-Awaited Treasury Regulations Address the Application of Section 1061 to Carried Interests |
On July 31, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REGS-107213-18) (Proposed Regulations) governing the treatment of “carried interests” (also referred to as “profits interests”) under Section 1061 of the Internal Revenue Code (the Code).
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Gain from the sale of capital assets held for more than one year (long-term capital gain) is generally taxed at preferential rates (currently 20%) for noncorporate taxpayers. Section 1061 increased the requisite holding period for such preferential rates from one year to three years with respect to gain attributable to “applicable partnership interests” (APIs).
Treasury Defends Dividend Deduction Rules as 'Narrowly Tailored' (1)
What Does IRS, Treasury Carbon Capture Tax Credit Guidance Mean For Future Energy Production?
Recent Treasury releases [i] gave taxpayers much-needed guidance in seeking to take advantage of tax credits [ii] under the Internal Revenue Code (“Code”) Section 45Q for successfully capturing and removing from the atmosphere qualified carbon oxide . There are two methods of sequestration of this gas rewarding the successful taxpayer (the owner of the sequestration equipment) as follows:
The allowable credit in each tax year is adjusted upward each year (for inflation) in a table set out in the regulations [iii] . Credits may be claimed in tax years through 2026, but only on construction beginning after February 9, 2018, and before January 1, 2024. If sequestration is not maintained (absent relief under EPA SubPart RR for Class II wells or ANSI ISO 27916:19), credits are recaptured as increases to tax liability measured using a five-year look-back period [iv] .
Low Interest Rates Make This A Great Time To Donate Part Of Your Home Or Farm
At least one of these tax benefits can be reaped without giving up immediately any cash or property: a charitable contribution of a remainder interest in a home, vacation home, or farm.
The amount of the tax deduction is the estimated present value of the charity's remainder interest. In other words, the deduction is an estimate of the value the charity will receive in the future. Tables and formulas in the IRS regulations are used to determine the present value. The amount of the tax deduction varies with your age and current interest rates.
Happening on Twitter
For one thing, Smith was on record to @dgelles justifying the indefensible carried-interest loophole that has let p… https://t.co/E1m0utXimF AnandWrites (from New York) Fri Aug 21 13:10:36 +0000 2020
@firstdogonmoon It may interest you to know that the chicken who demands to be carried over puddles has acquired a… https://t.co/lS4k9JQDGe jpwarren (from Planet 3, Sol System) Sat Aug 22 22:26:39 +0000 2020
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