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Equity Compensation Grants in Partnerships and LLCs: Overcoming Tax Challenges and Key Planning Techniques

Carried Interest, Section 83, Profits vs. Capital Interests, Options and Phantom Equity, and More

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.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Tuesday, September 17, 2024

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, August 23, 2024

or call 1-800-926-7926

This CLE/CPE course will provide tax counsel and advisers with a detailed analysis of the tax implications of equity compensation grants in partnerships and LLCs. The panel will discuss profit versus capital interests, phantom equity, the application of Section 83, carried interest, and best tax planning methods for compensatory interests and other arrangements.


There are several issues faced by partnerships and LLCs when handling equity compensation matters. These issues are unique to partnership and LLC equity compensation due to the differences in the tax regime applied to entities taxed as partnerships compared to those taxed as corporations. Tax counsel and advisers must have a thorough knowledge of the forms that equity compensation can take and applicable tax rules to avoid any unintended tax consequences.

Partnership and LLC equity compensation can take several forms, including granting profits interests, capital interests, and options to acquire such interests. Each arrangement has specific economic and tax implications, including whether to treat the grantee as an employee or a partner for tax purposes.

Also, tax counsel and advisers face additional challenges, including applying Section 83, significant changes to carried interest taxation, and the treatment of fee waivers. These and other issues present planning and compliance challenges to carefully consider.

Listen as our experienced panel offers a thorough and practical guide to planning considerations in partnership and LLC grants of equity compensation, phantom equity, the application of Section 83, and the impact of new carried interest rules.



  1. Types of equity compensation and alternatives for partnerships and LLCs
  2. Planning considerations under current tax law
  3. The impact of carried interest rules
  4. Reporting and compliance challenges for partners/members
  5. Best practices in structuring equity compensation arrangements to avoid unfavorable tax treatment


The panel will review these and other key issues:

  • Capital interest versus profits interest as equity compensation in partnerships and LLCs
  • Different planning methods based on the type of equity compensation
  • Application of Section 83 and unvested interests
  • Section 409A and compensatory grants of equity interests in partnerships and LLCs
  • Tax treatment of carried interest and fee waivers arising from compensatory grants of equity interests
  • Best practices and critical considerations for equity compensation grants in partnerships and LLCs


McDaniels, Laura
Laura L. McDaniels

Pillsbury Winthrop Shaw Pittman

Ms. McDaniels has over two decades of experience advising clients on compensation and benefits matters. She counsels...  |  Read More

Patel, Henrik
Henrik Patel

White & Case

Mr. Patel, a Partner with White & Case LLP, counsels clients on the full spectrum of executive compensation and...  |  Read More

Attend on September 17

Early Discount (through 08/23/24)

See NASBA details.

Cannot Attend September 17?

Early Discount (through 08/23/24)

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.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video