Hedge Funds and IRS Partnership Audit Rules
Advanced Tax Strategies in Structuring Private Investment Funds in Light of New IRS Rules
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax counsel with guidance on the impact of the IRS partnership audit rules on the structure and operations of hedge funds and private investment funds. The panel will discuss structuring considerations for new funds in light of the new regulations, and will detail necessary adjustments to the operating agreements of currently operating funds and partnerships.
Outline
- Balancing competing tax objectives of investors in structuring private investment funds
- Tax objectives of taxable U.S. investors
- Tax objectives of non-taxable U.S. investors (pension plans, endowments, other tax-exempt investors and governmental entities)
- Tax objectives on non-U.S. investors
- Tax objectives of sovereign investors
- Tax objectives of fund managers
- Fund structuring issues and options
- Structuring new private investment funds in light of the new partnership audit regulations
- Elections and steps tax counsel should consider now to protect existing hedge funds and private investment partnership funds
Benefits
The panel will review these and other critical issues:
- Structuring considerations to balance competing tax preferences of major private fund investors
- How can the use of blockers and feeder funds accommodate the needs of particular investors?
- What changes will the IRS partnership audit regulations bring to structuring new hedge fund and private investment fund partnerships?
- What elections and other steps should tax counsel be considering now for existing private investment fund partnerships to avoid negative tax and operational consequences?
- What challenges do sovereign investors face in retaining their status as Section 892 investors?
Faculty
Lawrence M. Hill
Partner
Winston & Strawn
Mr. Hill is a tax partner in the firm’s New York office. Previously, he served as a senior partner and global... | Read More
Mr. Hill is a tax partner in the firm’s New York office. Previously, he served as a senior partner and global head of tax controversy and litigation at several major international law firms. Earlier in his career, he was a trial attorney and National Tax Shelter Project Attorney with the Office of Chief Counsel of the Internal Revenue Service and a Special Assistant United States Attorney with the United States Attorney’s Office in Washington, DC. He also previously served as Assistant General Counsel to a “Big Four” accounting firm.
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Olga A. Loy
Partner
Winston & Strawn
Ms. Loy represents funds and fund sponsors in structuring, negotiating, and forming private equity and venture capital... | Read More
Ms. Loy represents funds and fund sponsors in structuring, negotiating, and forming private equity and venture capital funds. She plans and structures other complex business transactions, including corporate mergers and acquisitions, leveraged buyouts, recapitalizations, and venture capital investments. Furthermore, she counsels investment advisers, hedge funds, registered investment companies, and broker-dealers across a wide range of investment management, securities, and general corporate matters. She represents large and mid-size private equity funds and their management companies. She also advises real estate funds and investors in tax structuring matters, including REIT counsel and planning and cross-border analysis.
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Rachel Ingwer
Partner
Winston & Strawn
Ms. Ingwer concentrates her practice on transactional matters. She advises clients on a wide variety of private equity... | Read More
Ms. Ingwer concentrates her practice on transactional matters. She advises clients on a wide variety of private equity and other transactional issues (both domestic and cross-border), including business formations, taxable and tax-free mergers and acquisitions, divestitures, financings and restructurings and recapitalizations. Rachel also advises clients on debt and equity offerings, tax disclosures issues, and fund formation issues, including structuring and partnership matters. In addition, she advises high net worth individuals on individual and private foundation tax matters, as well as tax matters relating to their business interests.
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