Advanced Tax Strategies in Structuring Private Investment Funds: Balancing Competing Interests
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax counsel and advisers with advanced guidance on how to structure private equity and other types of investment funds. The panel will discuss critical considerations in light of new tax law and offer essential planning techniques to avoid tax pitfalls. The panel will also review critical factors, such as type of investor, type of fund and location of fund, and address fund manager and fund investor issues.
- The impact of tax reform
- Tax objectives of taxable U.S. investors
- Tax objectives of non-taxable U.S. investors (pension plans, endowments, other tax-exempt investors and governmental entities)
- Tax objectives on non-U.S. investors
- Tax objectives of sovereign investors
- Tax objectives of fund managers
- Fund structuring issues and options
The panel will review these and other vital questions:
- What are the competing tax preferences of major private fund investors that practitioners must juggle when structuring investment funds?
- How can the use of blockers and feeder funds accommodate the needs of particular investors?
- What challenges face sovereign investors in retaining their status as Section 892 investors?
- How do new tax rules impact tax planning when structuring private investment funds?
Christian M. McBurney
Mr. McBurney advises clients who seek to structure partnership transactions and draft tax provisions of partnership... | Read More
Mr. McBurney advises clients who seek to structure partnership transactions and draft tax provisions of partnership agreements. He also advises on all aspects of corporate transactions, including stock sales, asset sales, and tax-free mergers. Recently, he has focused on the tax reform act, structuring partnership profits interests, section 1031 exchanges, section 280G, S corporations, FIRPTA, FATCA, and both inbound and outbound cross-border transactions. He has extensive experience with U.S. and international private equity funds and other investment funds.Close
Mr. Naylor is a member of the firm’s Private Funds Group. He works with private investment fund sponsors and... | Read More
Mr. Naylor is a member of the firm’s Private Funds Group. He works with private investment fund sponsors and their investors in all tax aspects of structuring venture capital, private equity, real estate and hedge funds. Mr. Naylor also advises U.S. and non-U.S. institutional investors, governmental investors, pension trusts and other tax-exempt organizations in their investments in private funds and joint ventures. In addition, he works with his fund sponsor clients in designing and implementing carried interest plans and other compensation arrangements for the general partners of private funds.Close