Gain an understanding of critical fund structuring considerations in light of recent tax laws in order to better advise your clients.
Recent changes in the tax law require careful review of private investment fund and general partner structures, as well as consideration of potential amendments to the existing fund documentation to achieve tax efficiency. Many tax practitioners may not be aware of essential planning techniques to avoid tax pitfalls. This topic will review such factors as the type of investor, type of fund, location of fund, and general partner tax planning considerations. Fund professionals and advisers will benefit from this topic's general overview of the typical structures and a deeper dive into current tax issues, such as the impact of the CARES Act, proposed carried interest regulations, and potential changes to the tax rates. This information is critical for professionals trying to stay ahead of the changes and better serve their clients.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
Tax Structuring Considerations - Fund Level
- Choice of Entity
- Choice of Jurisdiction
- Advanced Structures: Parallel Funds, Master-Feeder Funds, Use of Blockers
Tax Structuring Considerations - Investor Level
- Tax Issues for U.S. Taxable Investors (Including Impact of Tax Reform)
- Tax Issues for U.S. Tax-Exempt Investors - UBTI and Structuring Solutions
- Tax Issues for Non-U.S. Investors - ECI and Structuring Solutions
Tax Structuring Considerations - General Partner and Fund Manager Level
- Carried Interest and Management Fee Structuring Considerations
- Tax Implications of the Grant of Profits Interests, Vesting Restrictions, Adding New Principals, and Other Common Manager Arrangements
- Proposed Section 1061 Carried Interest Regulations: Issues and Structuring Solutions
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on May 18, 2023.
Call 1-866-352-9540 for further credit information.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Olga A. Loy
Winston & Strawn LLP
- Co-chair of Tax Practice at Winston & Strawn LLP
- Represents funds and fund sponsors in tax structuring, negotiating, and forming private equity and venture capital funds
- Plans and structures other complex business transactions, including corporate mergers and acquisitions, leveraged buyouts, recapitalizations, and venture capital investments
- Counsels investment advisers, hedge funds, small business investment companies, registered investment companies, and broker-dealers across a wide range of investment management, securities, and general corporate matters
- Adjunct professor at the University of Illinois College of Law, where she teaches a course on private investment funds and introduces students to business, securities, and tax issues relating to private investment funds with an emphasis on private equity, venture capital, and hedge funds
- Prolific writer, speaker, and moderator on topics related to tax and fund programs and is regularly quoted in the press
- J.D. degree, magna cum laude, University of Illinois
- Can be contacted at [email protected] or 312-558-6338
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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