Tax Treatment of Partnership Profits Interests: Recent U.S. Tax Court Decision, IRS Safe Harbor, Tax Planning
An encore presentation with Q&A.
A 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE webinar will discuss the effects of granting, vesting, and selling profits interests in partnerships along with the benefits and burdens of awarding these equity rights. The panel will discuss the recent U.S. Tax Court decision in ES NPA Holding L.L.C. v. Commissioner, key tax considerations when structuring profits interests, and transfers for companies employing or considering this method of transferring partnership interests. The panel will also offer tactics for structuring compensation plans with profits interest and other incentives under current tax rules.
- Profits interest as compensation and alternatives for partnerships and LLCs
- ES NPA Holding L.L.C. v. Commissioner and Rev. Proc. 93-27
- Planning considerations under current tax law
- Reporting and compliance challenges
- Best practices in structuring equity compensation arrangements to avoid unfavorable tax treatment
The panel will review these and other key issues:
- Profits interest as equity compensation in partnerships and LLCs
- Available planning methods based on profits interest as compensation
- Tax treatment of profits interest and recent U.S. Tax Court decision in ES NPA Holding L.L.C. v. Commissioner
- Best practices and critical considerations for profits interest grants in partnerships and LLCs
An encore presentation featuring Q&A.
Timothy S. (Tim) Klimpl
Shipman & Goodwin
Mr. Klimpl is a seasoned attorney with experience providing ERISA advice and related services to a variety of plan... | Read More
Mr. Klimpl is a seasoned attorney with experience providing ERISA advice and related services to a variety of plan sponsors and employee benefit plans, including corporate, nonprofit, multiemployer and governmental plans providing retirement, health, disability, dental and other welfare benefits. In the field of executive compensation, he has assisted both employers and employees with equity and incentive compensation, nonqualified deferred compensation, Section 409A questions, and executive employment and severance agreements. Among other industries, Mr. Klimpl has represented clients in the financial, construction, medical, fashion, real estate and legal industries. He chairs the Fairfield County Bar Association Employment Law Committee.Close
Brianna L. Reed
Ms. Reed's practice focuses on tax planning for private investment funds, including fund formation, structuring and... | Read More
Ms. Reed's practice focuses on tax planning for private investment funds, including fund formation, structuring and internal organization, and investment activities. She also counsels clients who conduct secondary partnership transactions, including Strategic Partners and FlowStone Partners. In addition, Ms. Reed represents many types of investors with their investments in various private funds.Close
David B. Teigman
Mr. Teigman is a partner in the Tax Department and a member of the Employee Benefits & Executive Compensation... | Read More
Mr. Teigman is a partner in the Tax Department and a member of the Employee Benefits & Executive Compensation Group. He focuses his practice on executive compensation and benefit matters, principally in connection with mergers and acquisitions, securities offerings and senior executive employment relationships.Close
Cannot Attend October 26?
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.