Carried interest holding period
Profits interests need a three-year holding period for long-term capital gain treatment.
Industry tax guide
Tax planning for fee income, partner allocations and the software financial firms build.

Investment advisers, fund managers, broker-dealers and fintech companies earn management and performance fees, allocate income to partners in many states, and spend heavily on technology.
Their tax issues are specific: how carried interest is taxed, whether owners get the qualified business income deduction, and whether internal software development qualifies for the research credit.
Compared with a general business
Profits interests need a three-year holding period for long-term capital gain treatment.
Investment management and brokerage income is specified service income for the QBI deduction.
Funds issue K-1s to many investors, with tax basis capital accounts, state withholding and often foreign investor reporting.
Dealers and electing traders can use mark-to-market accounting, which changes the character and timing of gains.
The rules in detail
Gain allocated to a fund manager's profits interest is treated as long-term capital gain only if the underlying assets were held more than three years. Gains on assets held three years or less are taxed as short-term gain.
Investment management, brokerage and financial services are specified service trades. Owners above the income threshold lose the 20% qualified business income deduction for that income, which makes entity structure and owner compensation decisions more important.
Software built for a firm's own back-office use must pass a higher threshold of innovation test to qualify for the research credit. Software offered to clients, or used to interact with them, is evaluated under the regular rules.
Planning moves
Converting fees into profits interests can change ordinary income to capital gain when properly structured.
Entity-level state tax lets partners deduct state tax above the federal SALT cap.
Client-facing software and trading systems can qualify.
Owners below the threshold keep the deduction with the right salary and structure.
Cash balance plans allow large deductible contributions for senior partners.
Partners moving between states plan the move date and sourcing of carried interest.
Working with OICPA
Management fee waivers, profits interests and holding periods modeled before the year closes.
Business Tax AdvisoryClient-facing platforms and trading or risk systems reviewed for qualified research.
R&D Tax CreditFee reconciliations, accruals and entity-level reporting closed on a fixed calendar.
Month-End CloseComposite returns, withholding and PTET elections for partners who live in different states.
Multi-State Business Tax ComplianceBookkeeping and reporting
Reconcile receipts to agreements and document entity allocations; coordinate specialized regulatory matters with your compliance advisers.
Management fees, performance-linked receipts, shared costs, and multiple entities can make both revenue reconciliation and owner reporting difficult.
Fee agreements, custodian or platform statements, expense allocations, and partnership records give the review a practical starting point. We identify missing information before recommending changes.
It applies to profits interests held in connection with investment management services. Gains on assets the fund held for more than three years keep long-term treatment.
Below the income threshold, yes. Above the phase-out range it is lost for specified service income such as investment management.
It can. Software used with clients or third parties is tested under the regular four-part test; purely internal software must also meet the higher threshold of innovation test.
Rules reflect federal tax law as of November 2026.