Selected US Tax Developments: New Proposed Regulations Under the Section 1061 Carried Interest Rules
Bibliographic record
Abstract
The Tax Cuts and Jobs Act of 2017 added new section 1061 to the Internal Revenue Code. That provision added a three-year holding period for fund managers holding "carried interests" to qualify for long-term capital gain treatment. On August 14, 2020, the Internal Revenue Service published proposed regulations that provide much-needed guidance. As proposed, however, the new rules are quite complex and include a number of traps for the unwary. We discuss some of the key provisions of the proposed regulations and consider their impact for Canadian funds and their Canadian and US managers.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.016 | 0.030 |
| Meta-epidemiology (narrow) | 0.001 | 0.002 |
| Meta-epidemiology (broad) | 0.001 | 0.002 |
| Bibliometrics | 0.005 | 0.005 |
| Science and technology studies | 0.007 | 0.003 |
| Scholarly communication | 0.013 | 0.003 |
| Open science | 0.005 | 0.003 |
| Research integrity | 0.013 | 0.011 |
| Insufficient payload (model declined to judge) | 0.017 | 0.011 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".