Private Equity Associates ("Associates") is a limited partnership that buys, restructures, and then sells companies that are not publicly traded. Manager, the sole general partner of Associates, is entitled to an annual management fee equal to 2% of committed partnership capital. When Associates was formed on January 1, 2018, Manager also received a 20% profits interest, which is an "applicable partnership interest" within the meaning of Private Equity Associates ("Associates") is a limited partnership that buys, restructures, and then sells companies that are not publicly traded. Manager, the sole general partner of Associates, is entitled to an annual management fee equal to 2% of committed partnership capital. When Associates was formed on January 1, 2018, Manager also received a 20% profits interest, which is an "applicable partnership interest" within the meaning of 1061(c)(1). Manager made a 83(b) election and did not report any gross income in connection with his receipt of the profits interest.

On June 30, 2018, Associates purchased 100% of the stock of Private Corp. for $1 million. On October 1, 2020, Associates sold its Private Corp. stock for $11 million, realizing a $10 million long-term capital gain. Manager's 20% distributive share of that gain was $2 million.

(a) What is the tax character of Manager's $2 million distributive share?

(b) Same as (a), above, except Associates sold its stock in Private Corp. on March 31, 2021.

(c) Same as (a), above, except Associates sold its stock in Private Corp. on January 1, 2022.