Estate Planning and Carried Interest: Estate Tax Reduction Strategies for Private Equity and Hedge Fund Founders

Strategies for Wealth Transfer and Asset Protection to Avoid Adverse Tax Consequences

Recording of a 90-minute CLE/CPE webinar with Q&A


Conducted on Tuesday, August 1, 2017

Recorded event now available

or call 1-800-926-7926
Program Materials

This CLE/CPE webinar for estate planning counsel who advise—or want to advise—private equity and hedge fund founders will discuss the estate planning opportunities presented by carried interest. The panel will outline how planners can help structure founders’ transfers of carried interest to family members, dive into the particulars of Chapter 14 of the Internal Revenue Code, explore the unintended impact on founders’ estate planning, and discuss multidisciplinary strategies specialists are implementing for these high net worth clients.

Description

Virtually every private equity or hedge fund uses carried interest—a share in the fund’s profits in excess of a minimum return—as part of its economic structure. Because carried interest can appreciate substantially if a fund is successful, it is an ideal asset to plan for using in a variety of estate planning techniques.

Careful planning is required to take advantage of the opportunities that carried interest offers for transferring wealth. IRC Chapter 14 governs the valuation of certain lifetime transfers to family members.

Under a typical private equity or hedge fund structure, a founder’s transfer of carried interest to one or more family members may trigger gift tax consequences under Chapter 14 as well as under traditional gift tax principles. Strategic estate planning can help fund sponsors take advantage of certain transfer techniques to achieve tax savings.

Listen as our experienced panel discusses the estate planning opportunities presented by carried interest. The panel will discuss how a professional team of advisers can work together to provide private equity and hedge fund managers with bespoke carried interest planning techniques that take advantage of wealth transfer opportunities while avoiding unintended adverse tax consequences.

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Outline

  1. Overview of private equity and hedge fund structure and estate planning issues
  2. Discussion of IRC Chapter 14 and potential gift tax implications
  3. Unintended impact of carried interest on founders’ estate planning
  4. Strategies for avoiding unintended tax consequences

Benefits

The panel will review these and other key issues:

  • How can proper planning help avoid triggering adverse tax consequences under IRC §2701?
  • Which estate planning techniques are most effective for transferring carried interest?
  • How can a fund founder structure an investment to take advantage of the vertical slice exception?
  • Which “non-vertical” planning ideas should be considered?

Faculty

Marissa Dungey
Marissa Dungey

Partner
Withers Bergman

Ms. Dungey's practice focuses on transfer tax planning, estate planning and trust structuring for wealthy...  |  Read More

Kevin Matz
Kevin Matz

Partner
Stroock & Stroock & Lavan

Mr. Matz concentrates on domestic and international estate and tax planning, estate administration and related...  |  Read More

Cristine M. Sapers
Cristine M. Sapers

Partner
Loeb & Loeb

Ms. Sapers focuses her practice on sophisticated estate and tax planning for high-net worth individuals,...  |  Read More

Shishir Khetan
Shishir Khetan

Managing Director
Stout Risius Ross

Mr. Khetan is a Managing Director in the Valuation Advisory group. He has extensive global experience in corporate...  |  Read More

Other Formats
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Strafford will process CLE credit for one person on each recording. All formats include program handouts. To find out which recorded format will provide the best CLE option, select your state:

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