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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, April 21, 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 planners and advisers guidance on key challenges and planning considerations when incorporating private equity and qualified opportunity zone investments in estate planning. The panel will discuss the impact of private equity and qualified opportunity zone investments on estate planning, outline key tax regulations impacting estates, and explore effective transaction structures and planning techniques to manage both tax and non-tax issues.

Faculty

Kevin Matz
Miscellaneous
Lawrence M. Lipoff
Director
CohnReznick LLP

With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private client services to enable high-net-worth individuals and families to maximize their new or generational wealth. He provides strategic advice to his clients and their closely held businesses in the areas of income tax planning and compliance, estate planning and administration services, as well as family structure consulting. Through many years in practice, he synthesized the work of various related professionals, and their firms integrate several planning strategies into solutions that maximize value. Mr. Lipoff is a frequent lecturer and author of articles published through professional forums on topics including domestic and international - estate planning and fiduciary income taxation including constructive attribution rules for foreign trusts, Forms 3520 & 3520-A, Graegin Loans, business succession, generation-skipping transfers, Chapter 14 and carried interest estate planning for private investment fund principals, preferred freeze partnerships, and private placement life insurance.

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Description

If properly structured, investors in Qualified Opportunity Zone Funds (“QOZ Funds”) have tremendous planning opportunities for their interests. But significant nuances are presented, as the ordinary rules that apply to gifts of interests in partnerships, LLCs and other entities do not apply to transfers of interests in QOZ Funds unless the transfer is to a grantor trust. In addition, because the deferred gain amount that is invested in a QOZ Fund constitutes “income in respect of a decedent” upon the investor’s death, there is no step-up in basis upon death for QOZ Fund interests, which means that ordinary estate planning techniques need to be modified to take into account the need to fund a deferred tax liability that will become due following the investor’s death by no later than December 31, 2026.

This program will address the rules that trusts and estates counsel, and other estate planning and financial advisors, need to know in implementing a plan that involves investments in QOZ Funds. Special attention will be paid to the practical application of these rules, including state specific decoupling considerations, and what estate and financial planners need to know about these specialized rules. The panel will also address how investments in QOZ Funds may fit within the panoply of estate planning techniques that are commonly employed to facilitate the transfer of wealth, such as GRATs and installment sales to grantor trusts, and carried interest planning considerations where representing the fund manager that is sponsoring the QOZ Fund.

Listen as our experienced panel discusses estate planning challenges for qualified opportunity zone fund investments. The panel will discuss planning techniques that take advantage of wealth transfer opportunities while avoiding unintended adverse tax consequences.

Outline

  1. Applicable income, estate, and gift tax rules and issues, including income in respect of a decedent upon death ("IRD")
  2. Use of grantor trusts and other applicable estate planning techniques including GRATs, and planning for no step-up in basis upon death due to IRD
  3. Valuation issues and special rules
  4. Best practices and other challenges for estate planners

Benefits

The panel will review these and other key issues:

  • What are the income, estate, and gift tax ramifications of investing in QOZ Funds?
  • What are the available planning techniques for QOZ Fund investors and fund managers?
  • How can GRATs and defective grantor trusts, among other estate planning techniques, be utilized to minimize taxes, and what are the challenges?
  • 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 qualified opportunity zone and private equity interests
  • Understand key tax planning techniques for fund managers and limited partners
  • Ascertain how GRATs, CLATs, and defective grantor trusts can be used to minimize taxes
  • Recognize key valuation issues and their impact on overall 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 or public firm experience at mid-level within the organization, preparing complex tax forms and schedules, supervising other preparers/accountants. Working knowledge and understanding of tax credits, sourcing rules; foundational knowledge of basis calculations and capital gains tax.

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).