US Federal 2023-2024 Regular Session

US Federal Senate Bill S. 4123

Introduced
4/15/24  

Caption

Carried Interest Fairness Act of 2024

Impact

If enacted, SB4123 would primarily affect how income derived from investment services partnerships is taxed. The proposed legislation stipulates that gains and losses associated with investment services are to be treated as ordinary income or losses, regardless of traditional capital gains treatment. This adjustment is intended to align the tax implications for those earning income through service partnerships with those engaging in labor-intensive occupations, thus changing the overall landscape of taxation in the sector. Such a change could yield higher tax revenues for the government by reducing the tax advantages historically associated with carried interest.

Summary

SB4123, also known as the Carried Interest Fairness Act of 2024, seeks to amend the Internal Revenue Code, particularly in relation to the tax treatment of personal service income earned in pass-through entities. The bill emphasizes ensuring that carried interest income, typically employed by private equity and hedge fund managers, is taxed similarly to ordinary income rather than capital gains, which has been a point of contention in tax reform discussions. The bill represents an attempt to rectify perceived tax inequities and strengthen the fairness of the tax code for individuals earning income through partnerships providing investment management services.

Contention

The bill is likely to face significant debate as it addresses a long-standing loophole within the tax system. Proponents argue that it would create a more equitable tax structure and ensure that wealthier individuals pay their fair share based on their actual income earned through services rather than benefiting from lower capital gains rates. Conversely, opponents may argue that this could hinder investment and economic growth, particularly in sectors reliant on investment partnerships. The professional community, including financial firms and investment managers, has expressed concerns that altering the tax treatment of carried interests could adversely impact their compensation structures and overall industry dynamics, fostering resistance against its implementation.

Companion Bills

US HB2686

Related Ending Wall Street Tax Giveaway Act

US HB8201

Related Small Business Tax Relief Act

US HB9985

Related Stop Wall Street Looting Act

US SB5333

Related Stop Wall Street Looting Act

Similar Bills

US SB445

Carried Interest Fairness Act of 2025

US HB1091

Carried Interest Fairness Act of 2025

US HB9956

Bill Pascrell Ending Tax Giveaway Act

US HB3275

Small Business Tax Relief Act

MT HB463

Revise business laws relating to conversion of certain business entities

US HB2621

REAL AMERICA Act Reward Each American’s Labor And Make Every Rich Individual Contribute Again Act

US SB4330

Ending the Carried Interest Loophole Act

US SB3317

Ending the Carried Interest Loophole Act