Tax Planning and Reporting for Partnership Equity Compensation Grants
Basis Adjustments, Avoiding Gain Recognition, Section 83 Elections and Deferred Compensation Impact
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers to partnerships and LLCs with guidance on tax planning opportunities and reporting requirements involved in granting equity compensation as payment for services. The panel will detail the tax consequences of equity grants, available elections and required reporting under the new partnership audit regime. The panel will also discuss how recent changes to carried interest rules will affect equity grants.
Outline
- Equity compensation alternatives available to partnerships and LLCs
- Profits interests
- Capital interests
- Options to acquire capital or profits interests
- Phantom arrangements
- Planning and implementation considerations
- Section 409A applicability
- Impact of fee waiver proposed regulations
- Carried interest treatment
- Income tax reporting and compliance challenges
- Capital account book-ups and valuation elections
- Reporting profits interest vs. capital interest
- Reporting challenges for grants of equity interests to employees when partnership has unrealized appreciation in assets
- Impact of partner/member status on employee benefits
Benefits
The panel will review these and other key issues:
- How does a capital interest differ from a profit interest and how do tax reporting requirements and planning opportunities differ depending on the type of equity interest granted?
- How does Section 409A apply to compensatory grants of equity interests in partnerships and LLCs?
- Should a Section 83(b) election be made for unvested interests?
- Tax reporting and employee benefit plan issues when an equity interest is granted to a current employee of a partnership business
- Tax treatment of carried interest and fee waivers arising from compensatory grants of equity interests
Faculty
Adam S. Mendelowitz
Partner
Finn Dixon & Herling
Mr. Mendelowitz practices in the areas of executive compensation, employee benefits and ERISA. He has been part of... | Read More
Mr. Mendelowitz practices in the areas of executive compensation, employee benefits and ERISA. He has been part of teams advising a wide variety of clients, including both public and private companies and private equity firms, with respect to executive compensation and employee benefits aspects of mergers, acquisitions, dispositions and other strategic transactions.
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Michael P. Spiro
Partner
Finn Dixon & Herling
Mr. Spiro chairs the firm's Tax group, where his practice focuses on providing federal and state tax... | Read More
Mr. Spiro chairs the firm's Tax group, where his practice focuses on providing federal and state tax advice in connection with domestic and international transactions, including hedge and private equity fund formations, mergers and acquisitions, and debt and equity financings and restructurings.
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