IRS Final Carried Interest Regulations: Significant Tax Rule Changes and Planning Opportunities
An encore presentation featuring live Q&A
A 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will guide tax counsel and advisers on the IRS final regulations, the tax treatment of carried interest, and available planning opportunities. The panel will discuss the application of Sec. 1061, modifications to the capital interest exception, applicable partnership interests (API) dispositions, and other significant provisions. The panel will also discuss Sec. 1231 property, implications of related party transactions, and planning techniques to ensure favorable capital gains treatment.
- Overview of the requirements of obtaining capital gains treatment under IRC 1061
- Impact of recent IRS final regulations
- Determining "applicable partnership interest" and "applicable trade or business"
- Applicability of IRC 1061 to 1231 property
- Planning ideas for avoiding IRC 1061 three-year holding period
- Best practices for compensation arrangements in light of new holding requirements under IRC 1061
The panel will review these and other noteworthy issues:
- Treatment of carried interest and performance of services under IRC 1061
- Understanding key provisions of the IRS final regulations
- Available tax planning techniques and strategies for partnerships for more favorable tax treatment
- Determining partnership interest that is "applicable partnership interest" subject to IRC Section 1061 holding requirements
- Understanding key planning issues regarding the applicability of IRC 1061 to 1231 property
- Potential planning opportunities presented by special allocations, transfers to unrelated parties, capital contributions, and distributions
- Best practices in ensuring favorable tax treatment in compensation arrangements involving carried interest
This is an encore presentation with live Q&A.
Richard S. LeVine
Mr. LeVine's practice focuses on cross-border estate, gift and income tax planning for owners of privately held... | Read More
Mr. LeVine's practice focuses on cross-border estate, gift and income tax planning for owners of privately held companies and other high-net-worth U.S. and foreign individuals. He counsels clients on pre-immigration and pre-expatriation tax planning, offshore trusts and foundations deferred compensation planning for fund manager and structures involving life insurance. He has been heavily involved in advising clients on the IRS Voluntary Disclosure programs.Close
Fried Frank Harris Shriver & Jacobson
Mr. Penman's practice focuses on federal income taxation, with particular emphasis on partnership taxation and the... | Read More
Mr. Penman's practice focuses on federal income taxation, with particular emphasis on partnership taxation and the structuring and formation of private equity and hedge funds, including funds focused on equity, debt, infrastructure and real estate, as well as funds-of-funds. He has advised both fund sponsors and investors on the preparation and negotiation of fund disclosure, organizational documents, and side letter agreements.Close
Early Discount (through 06/04/21)
Cannot Attend June 29?
Early Discount (through 06/04/21)
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include program handouts.