- 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
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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
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.
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.
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.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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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.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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