Taxation of Equity Based Arrangements for LLCs: Capital and Profits Interest Transfers, Appreciation Rights
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will review how transfers of partnership interests to partners are taxed and reported. Our panel of astute federal tax experts will break down the tax treatment of these interests by type of arrangement, review Section 83(b) elections, and discuss recent court decisions pertaining to these transfers.
- Equity compensation incentives: an introduction
- Capital interests
- IRC Section 83(b) election
- Profits interests
- Appreciation and other arrangements
- Recent decisions
The panel will cover these and other key issues:
- How will TC Memo 2023-55 impact profits interests grants?
- What is considered a restriction on the transfer of a capital interest?
- When is the transfer of a profits interest taxed?
- Which members and partners are candidates for Section 83(b) elections?
- How does the partnership record the transfer of capital interest?
- How are appreciation rights taxed?
Joseph E. Hunt, IV, J.D., LL.M.
Morse Barnes-Brown & Pendleton
Mr. Hunt has eight years of advisory and legal experience, counseling startup, emerging, and middle-market companies... | Read More
Mr. Hunt has eight years of advisory and legal experience, counseling startup, emerging, and middle-market companies throughout all stages of the entity life cycle, including formation, tax structuring, issuing equity, venture capital financing, and mergers and acquisitions. His clients span a variety of different industries at all stages of corporate development, with a particular focus in serving technology and life sciences startup companies. Mr. Hunt is a member of the adjunct faculty at Boston University School of Law where he teaches in the Graduate Tax Program.Close
Barry L. Salkin
The Wagner Law Group
Mr. Salkin is an employee benefits attorney focusing on diversified employee benefits, compensation, ERISA,... | Read More
Mr. Salkin is an employee benefits attorney focusing on diversified employee benefits, compensation, ERISA, tax-qualified plans and welfare plans. He has published and presented at conferences on a wide array of ERISA issues including fiduciary litigation and the DOL fiduciary rule.Close
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CPE credit is not available on downloads.