Tax Strategies for Limited Partner Investors in Private Investment Funds
Avoiding Tax Traps Through Side Letters and Other "Hidden" Agreements
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide tax counsel and advisers with a detailed guide to the tax issues of various types of private investment funds, including private equity, venture capital, and real estate funds. The panel will discuss the tax implications of various fund structures, identify potential tax filing and payment obligations, and identify possible strategies for negotiating key fund provisions in both the fund agreement and in side letters.
Outline
- Structures and tax characteristics of private investment funds
- Venture capital
- Fund of funds
- Real estate
- Mezzanine debt
- Tax implications of investment strategies
- Carried interest considerations
- Tax distribution provisions
- Side letters and other negotiation strategies
Benefits
The panel will review these and other important issues:
- What are the structuring options and accompanying tax issues for taxpayers investing in private investment funds?
- How to identify "traps for the unwary" in terms of potential tax filing and payment obligations, both in the U.S. or foreign jurisdictions, and possible protective strategies
- How to design strategies for negotiating key tax provisions, whether in the fund agreement or in side letters
- How to identify and understand liability under subscription letters
- Updates on key changes in fund structure and tax treatment, including management fee waivers and carried interest
Faculty
Kathleen (Kat) Saunders Gregor
Partner
Skadden Arps Slate Meagher & Flom
Ms. Gregor focuses on partnership and international tax issues, particularly with respect to disputes with the IRS... | Read More
Ms. Gregor focuses on partnership and international tax issues, particularly with respect to disputes with the IRS and other administrative bodies. She regularly represents private investment funds, institutional investors, private companies and high net worth individuals and advises private investment fund managers on structuring and launching funds, working extensively on fund investment and secondary transactions. She also represents public and private clients in ongoing tax issues, as well as merger, acquisition and restructuring transactions. She previously practiced as a CPA with the Middle Market Advisory Services group of PricewaterhouseCoopers LLP.
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Elizabeth M. Norman
Managing Partner
Touchstone Strategic Law
Structuring of complex acquisitions and dispositions of domestic and international holdings, including public and... | Read More
Structuring of complex acquisitions and dispositions of domestic and international holdings, including public and private companies, partnerships and S corporations are just a few of the tax-related issues on which Ms. Norman advises clients. Ms. Norman also provides counsel on the tax aspects of domestic and international corporate restructurings, cross-border transactions, and policy and legislative changes to U.S. and non-U.S tax laws.
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