Carried Interest After Section 1061: How a Three-Year Holding Clock Converts Fund Managers’ Labor Income into Capital Gains

The Mechanism First, the Slogan Second Section 1061 of the Internal Revenue Code is usually described as Congress “closing the carried interest loophole.” That description is wrong in a way that matters for anyone trying to trace where money actually goes. Section 1061 did not end the preferential treatment of fund managers’ compensation. It re-timed […]

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Opportunity Zones: What Section 1400Z-2 Actually Requires — and What It Doesn’t

The Purpose Statement and the Compliance Tests Are Two Different Documents The Internal Revenue Service describes Qualified Opportunity Zones as “an economic development tool—that is, they are designed to spur economic development and job creation in distressed communities” (IRS Opportunity Zones FAQ). That sentence is the program’s public justification. It is not, however, a legal […]

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