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
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
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.
Outline
- Types of equity compensation and alternatives for partnerships and LLCs
- Planning considerations under current tax law
- The impact of carried interest rules
- Reporting and compliance challenges for partners/members
- Best practices in structuring equity compensation arrangements to avoid unfavorable tax treatment
Benefits
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
Faculty
Laura L. McDaniels
Partner
Pillsbury Winthrop Shaw Pittman
Ms. McDaniels has over two decades of experience advising clients on compensation and benefits matters. She counsels... | Read More
Ms. McDaniels has over two decades of experience advising clients on compensation and benefits matters. She counsels companies across multiple industries at all stages of their life cycle--from startups to multinational corporations--on both day-to-day matters and transformative events. Ms. McDaniels also advises boards of directors, executives and investors.
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Henrik Patel
Partner
White & Case
Mr. Patel, a Partner with White & Case LLP, counsels clients on the full spectrum of executive compensation and... | Read More
Mr. Patel, a Partner with White & Case LLP, counsels clients on the full spectrum of executive compensation and employee benefits issues. His significant experience and knowledge in this area has made him a valued resource for a range of US and international clients, including public and private companies, boards of directors and executives. Henrik regularly negotiates and drafts employment, retention, separation, equity, phantom equity, bonus, change of control, non-competition, non-solicitation and other compensation-related agreements, plans and provisions, as well as relevant sections of proxy statements, periodic and current reports and registration statements.
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