About the Course
Introduction
This CLE/CPE course will provide tax counsel guidance on tax compliance, reporting, and planning strategies for fund managers and investors of hedge funds under current tax law. The panel will discuss structuring considerations for new funds, navigating carried interest rules under Sec. 1061, management fees, receipt of profits interests and Rev. Proc. 93-27, the impact of the One Big Beautiful Bill Act (OBBBA), and other critical tax considerations for fund managers and investors.
Description
In structuring hedge funds, the competing tax preferences of different types of fund investors are critical. The different types include U.S. taxable, U.S. tax-exempt, U.S. government, non-U.S. taxable, non-U.S. pension funds, and non-U.S. sovereign investors. Fund structures can use "blockers" and feeder funds to address these various interests and minimize U.S. taxes.
Tax counsel must understand current issues, such as FATCA for non-U.S. investment entities and investors, the impact of OBBBA for both fund managers and fund investors, and carried interest rules.
The program will conclude with an overview of typical investment fund documents and tax provisions, such as those addressing effectively-connected income and unrelated business taxable income.
Listen as our panel provides an analysis of the different and competing tax preferences of fund investors and outlines sophisticated best practices for structuring hedge funds to accommodate the myriad interests of these investors.
Presented By
Mr. Gross is the chair of Kleinberg Kaplan’s Tax Department and has been advising fund clients and other clients at the firm since 1993. He provides advice on federal, state, local and international tax issues concerning hedge funds, private equity funds and real estate funds, in addition to other myriad tax issues confronting business entities and individuals. Mr. Gross counsels clients on structuring and restructuring funds; structuring investment managers and general partners; compensating managers and employees; investing in funds; and seeding, buying and selling management entities. He also advises clients on planning and structuring securities transactions, foreign investment in U.S. real estate, acquisitions and dispositions of assets, nonqualified deferred compensation, Puerto Rico tax planning, ERISA matters, and numerous other tax issues.
Mr. Shalam is a partner in our Tax practice. He advises clients on tax aspects of private investment fund formation and operation, as well as on mergers and acquisitions, joint ventures and operating agreements. Mr. Shalam's experience includes advising on fund, upper-tier management company, and co-investment structuring, drafting of governance documents, negotiating side letter agreements, and drafting and negotiating purchase and merger agreements.
Mr. Stahl is a Tax Partner in the Financial Services Group with more than 15 years of experience in the financial services sector focusing on financial services and investment management entities. He provides services to both start-ups and well-established clients that include hedge funds, private equity funds, and fund of funds. Mr. Stahl assists clients by providing tax consulting and compliance services. He works with clients on the tax implications of various types of securities transactions, general tax issues and planning opportunities that arise during the life cycle of a fund.
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
-
Date + Time
- event
Tuesday, July 7, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. The impact of OBBBA
II. Tax objectives of taxable U.S. investors
III. Tax objectives of non-taxable U.S. investors (pension plans, endowments, other tax-exempt investors and governmental entities)
IV. Tax objectives on non-U.S. investors
V. Tax objectives of sovereign investors
VI. Tax objectives of fund managers
VII. Fund structuring issues and options
The panel will review these and other vital questions:
- What are the competing tax preferences of fund investors that practitioners must juggle when structuring hedge funds?
- How can the use of blockers and feeder funds accommodate the needs of particular investors?
- What challenges face sovereign investors in retaining their status as Section 892 investors in light of recent regulations?
- How do the OBBBA tax rules impact tax planning when structuring hedge funds?
Related Courses
IRC Section 338(h)(10) and 336(e) Election Strategies for Tax Counsel
Tuesday, August 4, 2026
1:00 p.m. ET/10:00 a.m. PT
