Description
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 topics 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.
Date: 2023-05-18 Start Time: 1:00 PM ET End Time: 2:40 PM ET
Learning Objectives
* You will be able to define ECI, UBTI, blockers, masterfeeder funds, management fee waivers, profits interests, and capital interests.
* You will be able to describe key U.S. federal income tax considerations important to nonU.S. investors investing in U.S. private investment funds.
* You will be able to explain the difference between the tax treatment of funds that are engaged in a U.S. trade or business and funds that are treated as investors (and how to distinguish between the two).
* You will be able to review and comment on tax disclosures and tax risk factors in a private placement memorandum for a typical investment fund.