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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Thursday, July 21, 2022

  • schedule Time

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

  • timer Program Length

    110 minutes

Credit Information

  • 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).

$197.00
CPE
ALL

This course will provide fund managers and advisers with a practical guide to the challenges and planning opportunities found in the final regulations and the proposed tax changes to the carried interest rules.

Faculty

Irina Kimelfeld
Partner
Eisner Advisory Group, LLC

Ms. Kimelfeld is a Tax Partner and a member of the Financial Services Group. With over 25 years of experience, she provides tax planning and compliance services to private equity funds, hedge funds, funds of funds, investment advisors, and other financial services companies. Ms. Kimelfeld focuses on advising clients on tax implications of fund structuring, investment structuring, management company operations, and tax treatment of various types of securities transactions.

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Victoria Glover
Partner
Deloitte, LLC

Ms. Glover is a partner in Washington National Tax in both the Passthroughs Group and Tax Policy Group. She specializes in partnership taxation and provides insights on U.S. tax policy developments. Before returning to Deloitte, Ms. Glover served as the majority tax advisor for the US House Committee on Ways and Means. As majority tax advisor, she was responsible for developing and implementing changes to the tax code with respect to domestic businesses, including partnerships, in the Tax Cuts and Jobs Act of 2017. Ms. Glover is a frequent speaker at events sponsored by Deloitte and notable tax conferences. She also co-authors the online treatise, Federal Income Taxation of Passive Activities.

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Description

Carried interest refers to the compensation general partners of hedge, private equity, and real estate funds received for their fund management services. Historically, the general partner recipients of carried interest were able to treat these payments as long-term capital gain to the extent the underlying assets met the required holding period. Tax Cuts and Jobs Act of 2017 made significant changes to the tax treatment of carried interest. Final regulations issued in January of 2021 provided valuable guidance for application of the carried interest rules while still leaving a number of issues unresolved.

Listen as our experienced panel provides practical guidance on the recent regulations, the tax reporting, and planning challenges in the new carried interest rules and impending changes to Section 1061.

Outline

  1. Background
  2. Carried interest treatment in the final regulations
    1. APIs defined
    2. Capital interest exception
    3. The three-year holding period
    4. Capital interests acquired with loan proceeds
    5. Look-through rules
    6. Anti-avoidance rules
    7. Related party transfers
    8. Other provisions
  3. Tax reporting challenges involving carried interests
  4. Potential federal and state changes

Benefits

The panel will review these and other relevant topics:

  • Overview of Section 1061 and the final regulations issued January 2021
  • Capital interest exception
  • Transfers of carried interest, in particular, gain recognition on transfers to related parties
  • Treatment of seed investors and other persons who may indirectly participate in the carried interest (by invested capital rather than performing services)
  • Potential differences between state and federal tax treatment of carried interest

NASBA Details

 

Learning Objectives

After completing this course you will be able to:

  • Understand IRC 1061 and the final regulations issued in January 2021.
  • Establish whether a taxpayer has an applicable partnership interest (API).
  • Identify the rules relating to APIs and applicable trade or businesses (ATBs).
  • Recognize the five exceptions to the definition of an API.
  • Verify that the reporting rules are fulfilled.
  • Discern the impact of related party 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 or public firm experience at mid-level within the organization, preparing complex
    tax forms and schedules, supervising other preparers/accountants. Specific knowledge and understanding of partnership
    taxation, carried interests, applicable partnership interests (APIs), holding periods, related party transfers, and IRC 1961;
    familiarity with reporting rules governing carried interests and related party transfers.als.

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).