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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

    Tuesday, December 10, 2024

  • 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 webinar will address the complex rules surrounding the taxation of investment partnerships. Our panel will discuss how private equity and hedge funds are taxed, the latest guidance on taxation of carried interests, and utilizing Bermuda reinsurance to mitigate taxation. They will provide comprehensive examples of scenarios and strategies explaining the taxation of partners investing in these funds.

Faculty

Toni Mazzacca
Partner
Forvis Mazars, LLP

Ms. Mazzacca has over 20 years of experience delivering insightful local, federal and global tax services to clients in the financial services, capital markets, banking, insurance, real estate, investment management, and private equity industries. She has a substantial track record of helping clients improve their tax positioning at the local, national and international levels, including achieving compliance with ongoing changes in tax regulations worldwide.

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Vincent J. Cincotta
Director
Andersen Tax, LLC

Mr. Cincotta is a Director in the Alternative Investment Funds practice. He has over 20 years of experience with extensive knowledge of alternative investments and partnership taxation. During his career, Mr, Cincotta has focused primarily on providing tax compliance and consulting services to private equity funds, hedge funds, fund of funds, and hybrid funds. He specializes in tax planning, compliance, and advisory services and provides deep tax knowledge and a sophisticated understanding of his client’s tax and business needs.  

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Richard A. Cagnetta
Partner
Citrin Cooperman Advisors, LLC

Mr. Cagnetta is a partner focused on providing tax advisory and compliance services to the firm’s asset management clients including funds, management companies, and principal individual owners. He has significant experience in the areas of partnership and individual taxation, corporate taxation, and the taxation of financial products covering domestic, international, and state and local issues. Mr. Cagnetta was a tax principal at Untracht Early, which joined Citrin Cooperman in 2022. Prior to joining Untracht Early, he spent significant time at a Big Four accounting firm and two prominent hedge funds.

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Description

IRC Section 732 provides guidelines for tax-free distributions of property to partners. The exception to this treatment is the distribution of marketable securities. Section 731(c) dictates that distributions of marketable securities are treated as cash distributions to partners and thereby subject to tax. The exception to this exception is a distribution of marketable securities made to a qualified partner in an investment partnership. (IRC Sec731(c)(3)(A)(iii)).

Private investors might invest in a hedge fund or private equity funds. The former generally invests in publicly traded assets, while the latter invests in private businesses. Hedge funds typically focus on high-return, high-risk, shorter-term investments, while private equity investments target long-term growth investments. Fund managers often receive a carried or profits interest in exchange for services rendered to the partnership. These "applicable partnership investments" are subject to the carried interest provisions under IRC Section 1061. Section 1061 curbs long-term capital gains treatment for income received by partners who provide services. Partnership advisers, members, and managers need to understand the complex taxation principles surrounding investment partnerships.

Listen as our panel of federal taxation experts simplifies the complex rules surrounding taxation of hedge funds, private equity funds, and other investment partnerships.

Outline

  1. Taxation of investment partnerships: introduction
  2. Hedge funds
  3. Private equity
  4. Carried interest
  5. Other considerations
  6. Examples and strategies

Benefits

The panel will cover these and other critical issues:

  • The definition of an investment partnership under IRC Section 731
  • Key considerations for taxation of private equity funds
  • The latest guidance on Section 1061 carried interest
  • Utilizing Bermuda reinsurance to minimize taxation

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify applicable partnership interest under IRC Section 1061
  • Determine how distributions to partners from investment partnerships are taxed
  • Ascertain differences between private equity investments and hedge funds
  • Decide how planning strategies can help mitigate taxes paid by partners in investment funds

  • 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 preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of pass-through taxation, including taxation of partnerships, S corporations and their respective partners and shareholders.

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).