Hedge Funds and New IRS Partnership Audit Regulations
Advanced Tax Strategies in Structuring Private Investment Funds in Light of New IRS Rules
Recording of a 90-minute CLE/CPE webinar with Q&A
This CLE/CPE webinar will provide tax counsel with guidance on the impact of the new 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.
- 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
The panel will discuss 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 new 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?
Partner and Chair, Tax Controversy and Litigation Department
Shearman & Sterling
Mr. Hill is Global Head of the Tax Controversy and Litigation Group and Global Head of Financial Institutions for his... | Read More
Mr. Hill is Global Head of the Tax Controversy and Litigation Group and Global Head of Financial Institutions for his firm. He handles major controversy matters, with a focus on litigation, IRS controversy and white collar investigations. He also works on significant financial product tax disputes. He was formerly a trial attorney and National Tax Shelter Project Attorney with the Office of Chief Counsel, IRS and a Special Assistant United States Attorney with the United States Attorney’s Office in Washington, D.C.Close
Olga A. Loy
Jenner & Block
Ms. Loy focuses on all aspects of tax planning, private equity, regulatory and compliance work, merger and acquisitions... | Read More
Ms. Loy focuses on all aspects of tax planning, private equity, regulatory and compliance work, merger and acquisitions and fund formation matters. She 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. She also advises investment advisers, hedge funds, registered investment companies and broker-dealers across a broad range of investment management, securities and general corporate matters. In addition, she represents institutional investors in connection with their investment in funds and other types of investment pools.Close
James D. McCann
Kleinberg Kaplan Wolff & Cohen
Mr. McCann has extensive experience in the areas of domestic and international taxation. He counsels clients regarding... | Read More
Mr. McCann has extensive experience in the areas of domestic and international taxation. He counsels clients regarding all tax aspects of domestic and cross-border investments and business transactions; structuring, launching, and operating pooled investment vehicles, such as hedge funds and private equity funds; and various forms of business formation, financing and reorganization, such as mergers, acquisitions, partnerships and joint ventures. He also advises small and mid-cap public companies and government-owned businesses.Close