• videocam Live Webinar with Live Q&A
  • calendar_month December 10, 2026 @ 1:00 PM ET/10:00 AM PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparation - Pass Through
  • schedule 110 minutes

Taxation of Investment Partnerships: Hedge and Private Equity Funds, Carried Interest, Bermuda Reinsurance

About the Course

Introduction

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.

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.

Presented By

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.  

Steve Clayton
Managing Director
Andersen Tax, LLC

Mr. Clayton is a managing director in the Alternative Investment Funds practice. He has 11 years of experience providing tax compliance and consulting services for partnerships, including funds of funds, venture capital, and private equity funds. Mr. Clayton consults with clients on choice-of-entity considerations, foreign investment reporting and structuring, and Qualified Small Business Stock (QSBS) exclusions. His compliance work includes operating entities and investment fund management companies. In addition to his client work, Mr. Clayton has developed automation tools and best practices adopted by the national AIF practice. He regularly presents on tax technology in national webcasts and meetings. Mr. Clayton has also led national trainings on foreign investment reporting, Section 83(b) elections, and carried interest allocations.

Andrew Friedman
Director
Andersen Tax, LLC

Mr. Friedman is a director in the Alternate Investment Fund Services practice with 10 years of experience in tax compliance and tax planning for partnerships, including private equity funds, family offices, venture capital funds, and hedge funds. He has extensive experience managing the preparation of tax returns for investment funds, including compliance work for operating entities and investment fund management companies. Mr. Friedman advises clients on private equity investment acquisitions and dispositions, profits interest grants, family office investment structuring and management company allocations and funding, and entity choice considerations.

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).

Date + Time

  • event

    Thursday, December 10, 2026

  • schedule

    1:00 PM ET/10:00 AM PT

I. Taxation of investment partnerships: introduction

II. Hedge funds

III. Private equity

IV. Carried interest

V. Other considerations

VI. Examples and strategies

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


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.

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.

IRS Approved Provider

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 .