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Live Webinar

100-minute live streaming program
  • November 12
  • 1:00 - 2:40 pm EST

Advanced Tax Strategies in Structuring Private Investment Funds: Balancing Competing Interests

November 12

Gain an understanding on 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 review such factors as type of investor, type of fund and 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 the professionals trying to stay ahead of the changes and better serve their clients.

Learning Objectives

  • You will be able to define ECI, UBTI, blockers, master-feeder funds, management fee waivers, profits interests and capital interests.
  • You will be able to describe key U.S. federal income tax considerations important to non-U.S. investors investing in U.S. private investment funds.
  • You will be able to explain the difference between 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.

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Over 33 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 33 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

Live Webinar Registration

  • CPE 2.0 including Taxes 2
     
  • Lorman Education Services is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: https://www.nasbaregistry.org/cpas/complaints. For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 2.0 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Taxes for 2.0 hours. Prerequisite: basic knowledge of taxation. Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: Group Internet Based. Please refer to the information in this brochure for outline, course content and objectives. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state's regulatory board. Please note: In order to receive CPE credit for this course you MUST use the streaming audio option, as well as enable and complete the required progress checks.
     

Who should attend?

This live webinar is designed for accountants, tax managers, tax preparers, accounts payable professionals, bookkeepers, CFOs, controllers, business managers and owners, presidents, vice presidents, CEOs, operations managers and consultants.

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Why Lorman?

Over 33 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

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 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
  • Recent speaking engagements include "Qualified Small Business Stock, Carried Interest Tax Planning and Other Tax Considerations for PE Funds," 2020 NY SBIC CFO Fund Conference (January 22, 2020); "78th Institute on Federal Taxation," NYU Institute on Federal Taxation (October 20-25, 2019, November 10-15, 2019); "Tax Considerations for Private Equity Funds," 2019 SBIC Fund Conference (June 17-18, 2019); "Guaranteed Payments IRC 199A Regulations: Maximizing QBI Benefits," American Bar Association Tax Meeting (May 9-11, 2019); "Guaranteed Payments Under IRC 199A Regulations: Year-End Strategies to Maximize QBI Benefits,” Webinar, (December 3, 2018); "Tax Considerations for Private Equity Funds,", 2018 SBIC Fund Conference (June 18-19, 2018); "Implications of the Tax Reform for Private Equity Funds," PE CFO Roundtable Conference (November 8, 2018); "Tax Reform Implications - A Practical Guide for General Partners," SBIA Western Private Equity Conference (April 18, 2018)
  • J.D. degree, magna cum laude, University of Illinois
  • Can be contacted at 312-558-6338 and [email protected]
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Why Lorman?

Over 33 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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Product ID: 407017
Published 2020
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