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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Estate Planning

Date & Time
  • event Date

    Thursday, June 9, 2022

  • 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).

$297.00
CLE
CPE
ALL

This CLE/CPE course will provide estate planning counsel who advise owners of private equity and hedge fund interests guidance on the estate planning opportunities and challenges in the transfer of such interests. The panel will discuss the impact of final carried interest regulations, establishing the structure, and common techniques such as GRATs and installment sales, as well as discuss multidisciplinary strategies specialists are implementing for high net worth clients.

Faculty

Brent Berselli
Partner
Holland & Knight LLP

Mr. Berselli is a partner in Holland & Knight's Portland office and is a member of the firm's Private Wealth Services Practice Group. He serves as general counsel to wealthy individuals, their families and their businesses throughout the United States to design and implement sophisticated strategies integral to family wealth planning. High-net-worth individuals, including principals of private equity, venture capital and hedge fund firms, private and public company executives, real estate developers, entrepreneurs and business owners, turn to Mr. Berselli for advice and counsel in all aspects of wealth transfer strategies, income and transfer tax planning, philanthropy and business succession.

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David C. Jacobson
Partner
Meltzer, Lippe, Goldstein & Breitstone, LLP

Mr. Jacobson's practice encompasses all aspects of estate planning and has considerable expertise in minimizing the impact of transfer taxes upon the death of senior family members. He specializes in the structuring and implementation of sophisticated estate plans for both U.S. residents and non-residents. He also counsels individuals on sophisticated charitable giving techniques. His tax-exempt organizations practice includes the representation of public charities and private foundations, from formation through dissolution, monitoring compliance with state and federal regulations, and advising on administrative matters with particular emphasis on grant-making activities. He also advises on all aspects of complex estate and trust administration.

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Marc J. Bloostein
Miscellaneous

Mr. Bloostein has been practicing in the private client group since 1989, and has been a partner of the firm since 1997. He focuses on sophisticated estate planning, and his practice includes all aspects of trust and estate administration, advising fiduciaries and beneficiaries and serving as trustee for numerous family trusts.

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Description

Hedge fund managers and private equity interest holders have tremendous planning opportunities for their interests if properly structured. Estate planners must identify potential income, estate, and gift tax issues for holders of these interests and implement effective techniques to minimize or avoid unintended tax consequences.

Most private equity or hedge funds use carried interest--a share in the fund's profits more than a minimum return--as part of its economic structure. Because carried interest can appreciate substantially if a fund is successful, it is an ideal asset to plan for use in various estate planning techniques.

Careful planning is required to take advantage of the opportunities that carried interest offers for transferring wealth. IRC Chapter 14 governs the valuation of certain lifetime transfers to family members. A founder's transfer of carried interest to one or more family members may trigger gift tax consequences under Chapter 14 as well as under traditional gift tax principles.

Trusts and estates counsel must implement planning techniques to assist owners of hedge funds or private equity firms geared toward facilitating the transfer of wealth, including common techniques such as GRATs, installment sales, intra-family loans, the use of vertical slice safe harbor rules, and other available options.

Listen as our experienced panel discusses estate planning challenges for hedge fund and private equity interest holders. The panel will discuss planning techniques that take advantage of wealth transfer opportunities while avoiding unintended adverse tax consequences.

Outline

  1. Income, estate, and gift tax issues
  2. Use of GRATs, CLATs, and defective grantor trusts
  3. Planning with carried interests
  4. IRC Section 2701 and "vertical slice" planning
  5. Valuation issues

Benefits

The panel will review these and other key issues:

  • What are the income, estate, and gift tax ramifications of hedge fund transfers and private equity interests?
  • What are the available planning techniques for fund managers and limited partners?
  • How can GRATs, CLATs, and defective grantor trusts be utilized to minimize taxes, and what are the challenges?
  • What are the key planning considerations for carried interest, and what is the impact of recently finalized regulations?
  • What are the issues stemming from Section 2701 and the use of "vertical slice" transfers?
  • What are the valuation issues and their impact on overall planning?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify the income, estate, and gift tax ramifications of hedge fund transfers and private equity interests
  • Ascertain tax planning techniques for fund managers and limited partners
  • Understand how GRATs, CLATs, and defective grantor trusts are utilized to minimize taxes
  • Recognize key tax planning considerations for carried interest
  • Identify tax issues stemming from Section 2701 and the use of "vertical slice" transfers

  • 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, involved in sophisticated tax planning and reporting; supervisory authority over other attorneys/preparers/accountants. Knowledge and understanding of partnership and other pass-through entities, IRC 1061, 1231; familiarity with tax planning for hedge funds, private equity, and real estate professionals.

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).