Starting on page 191, the recently passed Senate Tax Bill would bring some change to the taxation of carried interest. The Senate Tax Bill would insert into the IRC a new Section 1061 - Partnership Interests Held in Connection with Performance of Services. This new section provides that, for applicable partnership interests, capital gains previously classified as long-term will be treated as short-term capital gain unless the gains were generated from assets held for more than three years.
The Senate passed its tax bill on December 2nd by a 51-49 margin. Some key points include: