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Highlights from the Proposed Carry Regulations

On July 31, Treasury published proposed regulations on the “three-year carry rule,” which was enacted in 2017 pursuant to Section 1061 of the Code. Generally, the proposed regulations follow Section 1061 by recharacterizing long-term capital gains as short-term capital gains (“1061 Recharacterization”) if the asset generating the gains has a holding period of three years or less and is recognized on or with respect to an “applicable partnership interest” (“API”).

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Pension Protection Act Affects Charitable Giving and Exempt Organizations


Time to Read: 1 minutes Practices: Tax

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In addition to reforming the employer-based pension system, the Pension Protection Act of 2006 contains important charitable giving incentives and exempt organization reforms. Among the significant provisions of the Act, which is expected to be signed into law shortly, is the IRA charitable rollover. For a thorough analysis of that and other provisions of the Act affecting charitable giving and exempt organizations, please click "Download PDF" to read Ropes & Gray's client alert.

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