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Final Section 1061 Carried Interest Regulations

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Thursday, July 21, 2022

Recorded event now available

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This course will provide fund managers and advisers with a practical guide to the challenges and planning opportunities found in the final regulations and the proposed tax changes to the carried interest rules.


Carried interest refers to the compensation general partners of hedge, private equity, and real estate funds received for their fund management services. Historically, the general partner recipients of carried interest were able to treat these payments as long-term capital gain to the extent the underlying assets met the required holding period. Tax Cuts and Jobs Act of 2017 made significant changes to the tax treatment of carried interest. Final regulations issued in January of 2021 provided valuable guidance for application of the carried interest rules while still leaving a number of issues unresolved.

Listen as our experienced panel provides practical guidance on the recent regulations, the tax reporting, and planning challenges in the new carried interest rules and impending changes to Section 1061.



  1. Background
  2. Carried interest treatment in the final regulations
    1. APIs defined
    2. Capital interest exception
    3. The three-year holding period
    4. Capital interests acquired with loan proceeds
    5. Look-through rules
    6. Anti-avoidance rules
    7. Related party transfers
    8. Other provisions
  3. Tax reporting challenges involving carried interests
  4. Potential federal and state changes


The panel will review these and other relevant topics:

  • Overview of Section 1061 and the final regulations issued January 2021
  • Capital interest exception
  • Transfers of carried interest, in particular, gain recognition on transfers to related parties
  • Treatment of seed investors and other persons who may indirectly participate in the carried interest (by invested capital rather than performing services)
  • Potential differences between state and federal tax treatment of carried interest


Glover, Victoria
Victoria Glover

Deloitte Tax

Ms. Glover is a partner in Washington National Tax in both the Passthroughs Group and Tax Policy Group. She specializes...  |  Read More

Kimelfeld, Irina
Irina Kimelfeld

Eisner Advisory Group

Ms. Kimelfeld is a Tax Partner and a member of the Financial Services Group. With over 25 years of experience, she...  |  Read More

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