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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

    Friday, January 10, 2025

  • 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 and advisers an in-depth analysis of estate and tax planning strategies and opportunities for private equity and real estate fund managers. The panel will outline how planners can help structure transfers of carried interest to family members, dive into the particulars of IRC Section 2701, address profits interests, review issues with preferred partnerships, and discuss multidisciplinary strategies specialists are implementing for these 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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Shishir R. Khetan
Managing Director
Stout Risius Ross, LLC

Mr. Khetan is a Managing Director in the Valuation Advisory group. He has extensive global experience in corporate finance, valuations and strategic planning. He has advised clients ranging from Fortune 500 companies to medium and small privately held companies, private equity and investment funds, family offices, and accounting, legal and tax advisors. He has over two decades of financial advisory experience covering many industries, resulting in a comprehensive understanding of valuation concepts, capital markets, financial and economic analyses.

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Description

Private equity and real estate fund managers 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 real estate funds use a management fee structure or carried interest--a share in the fund's profits more than a minimum return--as part of its economic structure providing revenue and other assets and equity to fund managers. Because these interests can appreciate substantially if a fund is successful, they are ideal assets to plan for use in various estate planning techniques.

Careful planning is required to take advantage of the opportunities that carried interest and other equity or assets stemming from being a fund manager offers for transferring wealth. IRC Chapter 14 governs the valuation of certain lifetime transfers to family members. A fund manager's transfer of 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 managers of real estate 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 real estate 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
  5. Valuation issues

Benefits

The panel will review these and other key issues:

  • Income, estate, and gift tax ramifications of fund transfers and private equity interests
  • Utilizing GRATs, CLATs, and defective grantor trusts to minimize taxes
  • Key planning considerations for carried interest
  • Issues stemming from Section 2701
  • Valuation issues and their impact on overall planning

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Recognize the income, estate, and gift tax ramifications of fund transfers and private equity interests
  • Understand how utilizing GRATs, CLATs, and defective grantor trusts can minimize taxes
  • Identify the tax planning issues stemming from carried interest and methods to minimize taxes
  • Understand key tax issues stemming from Section 2701
  • Recognize valuation issues and their impact on overall tax and estate planning

  • 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).