Tax Considerations for Up-C Structures and Transactions: Tax Receivable Agreements, Equity Rollovers, and More
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will provide an in-depth analysis of key tax considerations for Up-C structures and transactions involving Up-Cs. The panel will discuss legal and tax challenges unique to Up-C structures, terminating or amending the tax receivable agreements, rolling over existing equity interests in a tax-deferred transaction, withholding tax considerations, calculating gain, and other tax considerations.
- Tax issues for Up-Cs
- Tax receivable or tax protection agreements
- Sec. 162(m); compensation paid by partnerships in Up-C
- Gains; withholdings; and other tax considerations
- Best practices for tax professionals
The panel will review these and other key issues:
- What are the key tax considerations for establishing Up-C structures?
- What are common terms of tax receivable agreements in these structures?
- What issues commonly arise when investors seek to acquire public businesses structured as Up-Cs?
Margaret R.T. Dewar
Kirkland & Ellis
Ms. Dewar is a partner in the tax group in Kirkland’s Chicago office. Her practice focuses on the federal income... | Read More
Ms. Dewar is a partner in the tax group in Kirkland’s Chicago office. Her practice focuses on the federal income tax consequences of complex business transactions, including mergers, acquisitions, joint ventures and spin-offs, both domestic and cross-border. Ms. Dewar also advises U.S. and non-U.S. fund sponsors and investors on the tax aspects of forming and operating private investment funds.Close
Adam D. Greenwood
Ropes & Gray
Mr. Greenwood is a partner practicing in the tax & benefits department. His practice focuses on transactional tax... | Read More
Mr. Greenwood is a partner practicing in the tax & benefits department. His practice focuses on transactional tax matters, including matters relating to private equity, real estate and hedge funds; mergers and acquisitions; inbound and outbound investments; and secondary transactions.Close
Cannot Attend April 18?
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 course handouts.