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Ezra Dyckman and Charles S. Nelson Ezra Dyckman and Charles S. Nelson

Before 2017, if a taxpayer received a “carried interest” in a partnership and held that interest for at least one year, the taxpayer would generally receive long-term capital gain treatment on a sale or redemption of such interest. In 2017, Congress enacted P.L. 115-97, which added new Section 1061 to the Internal Revenue Code. Section 1061 generally imposes a three-year holding period requirement in order for any capital gains with respect to carried interests to be treated as long-term capital gains.

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