Share with your friends

Final regulations on “carried interest” provision under section 1061 (text of regulations)

Final regulations on “carried interest” provision

The IRS today posted to its website a version of the final regulations (T.D. 9945) under section 1061—that is, the “carried interest” provision added to the Code by the 2017 U.S. tax law (Pub. L. No. 115-97) or the law often referred to as the “Tax Cuts and Jobs Act” (TCJA).


Related content

Read the final regulations [PDF 585 KB] (168 pages)

The version of the final regulations released today by the IRS includes the following statement:

This document has been submitted to the Office of the Federal Register (OFR) for publication and will be pending placement on public display at the OFR and publication in the Federal Register. The version of the final rule released today may vary slightly from the published document if minor editorial changes are made during the OFR review process. The document published in the Federal Register will be the official document.

These regulations finalize regulations that were proposed during the summer 2020. Read an KPMG report (August 2020) [PDF 383 KB] that discusses the proposed regulations under the carried interest provision. According to the preamble to the final regulations, the final regulations retain the structure of the proposed regulations, but “include multiple substantive changes compared to the proposed regulations.”

The purpose of this report is to provide text of the final regulations as released by the IRS.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal