Advanced Tax Strategies in Structuring Private Investment Funds: Balancing Competing Interests

A live 90-minute premium CLE/CPE video webinar with interactive Q&A

This program is included with the Strafford CLE Pass. Click for more information.
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Thursday, February 17, 2022

1:00pm-2:30pm EST, 10:00am-11:30am PST

or call 1-800-926-7926

This CLE/CPE course will provide tax counsel and advisers with advanced guidance on structuring private equity and other types of investment funds. The panel will discuss critical considerations in light of the new tax law and address fund manager and fund investor issues.

Description

In structuring private equity funds, the competing tax preferences of different types of fund investors are critical. The different types include U.S. taxable, U.S. tax-exempt, U.S. government, non-U.S. taxable, non-U.S. pension funds, and non-U.S. sovereign investors. Fund structures can use "blockers" and feeder funds to address these various interests and minimize U.S. taxes.

Our panel will outline structures typically used, taking into account the type of U.S.-based funds, such as standard private equity, distressed debt, hedge, and U.S. real property.

Tax counsel must also understand current issues, such as FATCA for non-U.S. investment entities and investors, the impact of tax reform for both fund managers and fund investors, and carried interest rules.

The program will conclude with an overview of typical investment fund documents and tax provisions, such as those addressing effectively connected income (ECI) and unrelated business taxable income (UBTI). The panel will also discuss qualified small business stock and opportunity zone funds.

Listen as our authoritative panel of practitioners provides a high level analysis of the different and competing tax preferences of fund investors and outlines sophisticated best practices for structuring investment funds to accommodate the myriad interests of these investors.

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Outline

  1. The impact of tax reform
  2. Tax objectives of taxable U.S. investors
  3. Tax objectives of non-taxable U.S. investors (pension plans, endowments, other tax-exempt investors, and governmental entities)
  4. Tax objectives on non-U.S. investors
  5. Tax objectives of sovereign investors
  6. Tax objectives of fund managers
  7. Fund structuring issues and options

Benefits

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?

Faculty

Illiparambil, Nitin
Nitin Illiparambil, CPA, MST
Senior Tax Manager
Grant Thornton

Mr. Illiparambil is a Senior Tax Manager and member of the Privately Held Business Group, with over eight years of...  |  Read More

Kim, Sharon
Sharon Kim

Partner
Ashurst

Ms. Kim advises the firm's leading financial institution and investment fund clients and investors on the U.S. tax...  |  Read More

Attend on February 17

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Cannot Attend February 17?

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

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