Private Investment Funds and Tax Reform
Carried Interest, QBI and Interest Deductions, Sale of Partnership Interests, Computation of UBTI, and More
Recording of a 90-minute CLE/CPE webinar with Q&A
This CLE/CPE webinar will provide private equity counsel with a working knowledge of the key provisions of the Tax Cuts and Jobs Act for the private investment fund industry.
- Tax reform bill—background and timeline for implementation
- Carried interest
- 20% Deduction on qualified business income
- Gain on sale of interest in partnership engaged in a U.S. trade or business treated as ECI
- UBTI computed separately for each trade or business activity
- Changes to interest deductibility—implications not only for portfolio companies and leveraged “blocker” corporations
- Limitation on excess businesses’ losses for taxpayers other than corporations
- Expansion of controlled foreign corporation rules
The panel will review these and other highly relevant issues:
- How does the 20% qualified business income deduction work and what constitutes “qualified business income”?
- How might the new carried interest provisions affect fund sponsors and the alignment of interests between fund sponsors and fund investors?
- How are foreign investors and tax-exempt investors in private equity funds impacted by the new tax law?
- How might changes in interest deductibility and the new corporate tax rate affect fund and investment structures?
Brian D. Huber
Mr. Huber's primary focus is tax planning for a broad range of private fund clients. He advises private equity fund... | Read More
Mr. Huber's primary focus is tax planning for a broad range of private fund clients. He advises private equity fund managers on tax aspects of fund-raising and internal organizational matters, as well as investment activities. He represents U.S. and non-U.S. investors in connection with the tax and economic aspects of their investments in venture capital funds, buyout funds, hedge funds and other investment partnerships. He regularly advises on international tax issues that arise in connection with investments in the U.S. by non-U.S. investors, as well as investments outside of the U.S. by U.S. persons. He also has significant experience advising clients on tax aspects associated with secondary purchases and sales.Close
Mr. Naylor is a member of the firm’s Private Funds Group. He works with private investment fund sponsors and... | Read More
Mr. Naylor is a member of the firm’s Private Funds Group. He works with private investment fund sponsors and their investors in all tax aspects of structuring venture capital, private equity, real estate and hedge funds. Mr. Naylor also advises U.S. and non-U.S. institutional investors, governmental investors, pension trusts and other tax-exempt organizations in their investments in private funds and joint ventures. In addition, he works with his fund sponsor clients in designing and implementing carried interest plans and other compensation arrangements for the general partners of private funds.Close