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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Tuesday, September 17, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00
CLE
CPE
ALL

This CLE/CPE course will provide tax counsel and advisers with a detailed analysis of the tax implications of equity compensation grants in partnerships and LLCs. The panel will discuss profit versus capital interests, phantom equity, the application of Section 83, carried interest, and best tax planning methods for compensatory interests and other arrangements.

Faculty

Henrik Patel
Partner
White & Case LLP

Mr. Patel, a Partner with White & Case LLP, counsels clients on the full spectrum of executive compensation and employee benefits issues. His significant experience and knowledge in this area has made him a valued resource for a range of US and international clients, including public and private companies, boards of directors and executives. Henrik regularly negotiates and drafts employment, retention, separation, equity, phantom equity, bonus, change of control, non-competition, non-solicitation and other compensation-related agreements, plans and provisions, as well as relevant sections of proxy statements, periodic and current reports and registration statements.

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Laura L. McDaniels
Partner
Pillsbury Winthrop Shaw Pittman LLP

Ms. McDaniels has over two decades of experience advising clients on compensation and benefits matters. She counsels companies across multiple industries at all stages of their life cycle--from startups to multinational corporations--on both day-to-day matters and transformative events. Ms. McDaniels also advises boards of directors, executives and investors.

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Description

There are several issues faced by partnerships and LLCs when handling equity compensation matters. These issues are unique to partnership and LLC equity compensation due to the differences in the tax regime applied to entities taxed as partnerships compared to those taxed as corporations. Tax counsel and advisers must have a thorough knowledge of the forms that equity compensation can take and applicable tax rules to avoid any unintended tax consequences.

Partnership and LLC equity compensation can take several forms, including granting profits interests, capital interests, and options to acquire such interests. Each arrangement has specific economic and tax implications, including whether to treat the grantee as an employee or a partner for tax purposes.

Also, tax counsel and advisers face additional challenges, including applying Section 83, significant changes to carried interest taxation, and the treatment of fee waivers. These and other issues present planning and compliance challenges to carefully consider.

Listen as our experienced panel offers a thorough and practical guide to planning considerations in partnership and LLC grants of equity compensation, phantom equity, the application of Section 83, and the impact of new carried interest rules.

Outline

  1. Types of equity compensation and alternatives for partnerships and LLCs
  2. Planning considerations under current tax law
  3. The impact of carried interest rules
  4. Reporting and compliance challenges for partners/members
  5. Best practices in structuring equity compensation arrangements to avoid unfavorable tax treatment

Benefits

The panel will review these and other key issues:

  • Capital interest versus profits interest as equity compensation in partnerships and LLCs
  • Different planning methods based on the type of equity compensation
  • Application of Section 83 and unvested interests
  • Section 409A and compensatory grants of equity interests in partnerships and LLCs
  • Tax treatment of carried interest and fee waivers arising from compensatory grants of equity interests
  • Best practices and critical considerations for equity compensation grants in partnerships and LLCs

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Recognize the tax implications of capital interest versus profits interest as equity compensation in partnerships and LLCs
  • Acquire planning methods for different forms of equity compensation
  • Understand the application of Section 83 and Section 409A to grants of equity compensation
  • Recognize the tax treatment of carried interest and fee waivers arising from compensatory grants of equity interests following tax reform

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business, legal or public firm experience at mid-level within the organization, providing tax planning and preparing complex tax forms and schedules for partnerships and LLCs; supervisory authority over other preparers/accountants. Knowledge and understanding of partnership and LLC structure, equity compensation in these entities; familiarity with equity compensation alternatives and equity interest for pass-through entity employees, members and partners.

Strafford Publications, Inc. 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 Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).