Investment Fund Tax Compliance and Planning: New IRS Guidance and Pitfalls to Avoid
IRS Notice 2026-62, Revenue Ruling 2026-20, Section 351 Conversion Transactions, and More
About the Course
Introduction
This CLE/CPE webinar will provide tax professionals and fund managers a detailed analysis of the complex rules surrounding the taxation of investment funds and recent IRS guidance regarding certain tax strategies. Our panel will discuss how investment funds are taxed and the latest guidance on the taxation of certain investment funds provided in IRS Notice 2026-62 and Revenue Ruling 2026-20. They will provide comprehensive examples of scenarios and strategies explaining the taxation of partners investing in these funds, reporting, and tax compliance.
Description
On Sept. 28, 2026, the IRS issued Notice 2026-62 focused on certain tax strategies used by investment funds that the IRS considered to potentially result in the misapplication of certain tax rules under the Internal Revenue Code. In addition, they also released Revenue Ruling 2026-20 specifically aimed at the use of Section 351 conversion transactions for a newly formed exchange-traded fund (ETF).
In structuring investment 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. However, the aforementioned IRS guidance forces tax professionals and fund managers to review current fund structures and the use of certain tax strategies to ensure intended tax savings and tax compliance.
The IRS guidance outlines key issues stemming from inconsistent application of Section 351 regarding conversion transactions for ETFs, treatment of contributions under Section 721, and other fund strategies that tax counsel must consider to minimize IRS scrutiny and potential tax liability.
Listen as our panel provides an analysis of the latest guidance on the taxation of certain investment funds provided in IRS Notice 2026-62 and Revenue Ruling 2026-20 and outlines best practices for structuring investment funds to accommodate the myriad interests of these investors in light of recent IRS guidance.
Presented By
Ms. Kim advises on a broad range of transactions across the firm's global offices. Her practice focuses on cross border investment, financing, and capital markets transactions, including advising issuers on structured notes programmes and trades, and advising UK and European fund managers with formation and operational matters, and non-US institutional investors such as pension funds, sovereign entities, and fund managers on private equity and other investment transactions, including US PPP infrastructure projects. Ms. Kim has extensive experience advising on debt and equity issuances, derivatives/ISDA documented transactions, and credit facilities. She has also advised issuers on securitization and structured finance transactions, including CLOs and REMICs.
.jpg)
Mr. Virmani counsels investment fund sponsors on the domestic and international tax aspects of forming, organizing and operating venture capital funds, private equity funds, real estate funds, hedge funds, debt funds and funds of funds. He frequently represents clients with respect to general partner-led fund restructurings, US and non-US investor representations, secondary transactions and minority investments in fund sponsors. In addition, Mr. Virmani often advises founders on the establishment of their investment management firms, including advising them on the organizational structure, employment matters, carried interest allocations and capital commitment funding strategies.
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
-
CPE credit is not available on recordings.
-
BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.
-
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
-
Date + Time
- event
Tuesday, December 8, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Tax objectives of taxable U.S. investors
II. Tax objectives of non-taxable U.S. investors (pension plans, endowments, other tax-exempt investors and governmental entities)
III. Tax objectives on non-U.S. investors
IV. Notice 2026-62
V. Revenue Ruling 2026-20
VI. Fund structuring issues and options in light of recent IRS guidance
The panel will review these and other vital questions:
- What are the key areas of interest and unresolved tax issues stemming from IRS Notice 2026-62 and Revenue Ruling 2026-20?
- What are the competing tax preferences of fund investors that practitioners must juggle when structuring investment funds?
- How can tax counsel, fund managers, and investors ensure tax savings and tax compliance in light of the recent guidance?
Learning Objectives
After completing this seminar, you will be able to:
- Determine the tax structure of investment funds
- Recognize various factors in tax planning when structuring investment funds
- Identify key tax provisions under current tax law impacting investment funds
- Ascertain tax planning methods to avoid tax pitfalls in structuring 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 sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.
BARBRI, 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.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .
Related Courses
Investment Fund Tax Compliance and Planning: New IRS Guidance and Pitfalls to Avoid
Tuesday, December 8, 2026
1:00 PM ET/10:00 AM PT
