Estate Planning and Carried Interest: Estate Tax Reduction Strategies for Private Equity and Hedge Fund Sponsors
Strategies for Wealth Transfer and Asset Protection to Avoid Adverse Tax Consequences
Note: CPE credit is not offered on this program
Recording of a 90-minute CLE video webinar with Q&A
This CLE course for estate planning counsel who 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.
Outline
- Overview of private equity and hedge fund structure and estate planning issues
- Discussion of IRC Chapter 14 and potential gift tax implications
- The unintended impact of carried interest on founders' estate planning
- Strategies for avoiding unintended tax consequences
Benefits
The panel will review these and other relevant issues:
- How can proper planning help avoid triggering adverse tax consequences under IRC Section 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?
- What are the principal "non-vertical" planning ideas to consider?
- What is the impact on estate planning of the final regulations under IRC Section 1061 that were released in January 2021 concerning the income taxation of carried interests in private investment funds?
Faculty
Marissa Dungey
Partner
Dungey Dougherty
Ms. Dungey's practice focuses on transfer tax planning, estate planning and trust structuring for wealthy... | Read More
Ms. Dungey's practice focuses on transfer tax planning, estate planning and trust structuring for wealthy individuals and their families. She works with individuals and their advisors to develop and implement sophisticated planning strategies designed to minimize gift, estate and generation-skipping transfer taxes with trust planning optimized to achieve the individual's tax and non-tax goals, including creditor protection, charitable giving and income tax efficiency. She regularly advises on planning with complex assets including interests in hedge funds, private equity funds and family businesses. She also advises on estate and trust administration matters, including adapting existing trusts to improve their tax efficiency and utility.
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Shishir R. Khetan, CFA
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
Mr. Khetan is a Managing Director in the Valuation Advisory group. He has extensive global experience in corporate finance, valuations and strategic planning. He has advised clients ranging from Fortune 500 companies to medium and small privately held companies, private equity and investment funds, family offices, and accounting, legal and tax advisors. He has over two decades of financial advisory experience covering many industries, resulting in a comprehensive understanding of valuation concepts, capital markets, financial and economic analyses.
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Kevin Matz, Esq., CPA, LL.M. (Taxation)
Partner
ArentFox Schiff
Mr. Matz concentrates on domestic and international estate and tax planning, estate administration and related... | Read More
Mr. Matz concentrates on domestic and international estate and tax planning, estate administration and related litigation. His practice primarily involves advising high net worth individuals with respect to wealth transfer planning; will and trust drafting; gift, estate, income and generation-skipping transfer tax planning and tax return preparation; charitable gift planning; probate proceedings and estate administration; and associated litigation as well as corporate counseling. He has also advised clients on entity and succession planning, including the use of family limited partnerships, the use of grantor retained annuity trusts, transfers to irrevocable trusts involving complex valuation issues, qualified personal residence trusts, irrevocable life insurance trusts, and the use of charitable remainder trusts, charitable lead trusts and private foundations to further both family planning and philanthropic objectives.
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Cristine M. Sapers
Co-Chair, Trusts & Estates
Loeb & Loeb
Ms. Sapers focuses her practice on sophisticated estate and tax planning for high-net worth individuals,... | Read More
Ms. Sapers focuses her practice on sophisticated estate and tax planning for high-net worth individuals, preparation of wills and trusts and the administration of large trusts and estates. Her area of specialty is working with hedge fund managers and principals of private equity firms on estate planning transfers of interests in their investment funds, including their carried interests. She has substantial experience handling IRS gift and estate tax audits and negotiating and resolving trust and estate disputes. She also counsels donors on charitable giving and advises private foundations and public charities on tax law, nonprofit corporation law and other matters.
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