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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Preparer

Date & Time
  • event Date

    Tuesday, March 26, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    110 minutes

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).

$197.00
CPE
ALL

This course will provide fund managers and their advisers with a practical guide to the challenges and planning opportunities found in the carried interest regulations.

Faculty

Brian T. Lovett
Partner
Withum Smith + Brown, PC

Mr. Lovett has extensive experience serving the tax needs of both public companies and closely-held businesses, including all aspects of tax compliance for partnerships and corporations. He advises clients with regard to the structure and tax consequences of new business ventures, and assists with restructuring existing businesses for increased tax efficiency. Prior to joining his firm, he was with a “Big 4” accounting firm, working closely with large, multinational real estate investment companies.

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Irina Kimelfeld
Partner
Eisner Advisory Group, LLC

Ms. Kimelfeld is a Tax Partner and a member of the Financial Services Group. With over 25 years of experience, she provides tax planning and compliance services to private equity funds, hedge funds, funds of funds, investment advisors, and other financial services companies. Ms. Kimelfeld focuses on advising clients on tax implications of fund structuring, investment structuring, management company operations, and tax treatment of various types of securities transactions.

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Description

IRC Section 1061 passed as part of the Tax Cuts and Jobs Act (TCJA) and related regulations made fundamental changes to the tax treatment of carried interest granted to managers of hedge funds, private equity, and real estate funds and present tax reporting and planning challenges to partnerships and their tax advisers.

Carried interest refers to the practice of granting profits interests to general partners and others for their fund management services The grant of profits interest is, generally, not subject to tax upon either grant or vesting.

Prior to the passage of TCJA in 2017, the recipients of carried interest were able to treat their share of allocated capital gains generated by the funds as long-term capital gain to the extent the assets generating the gain were held for greater than one year.

IRC Section 1061 passed as part of the TCJA and related regulations did not eliminate the carried interest preference entirely but made several fundamental changes. Section 1061 regulations provide extensive guidance on how the carried interest rules should be applied while still leaving a number of issues unresolved.

Listen as our experienced panel provides practical guidance on the carried interest regulations and the tax reporting and planning challenges contained in these rules.

Outline

  1. Background
  2. Carried interest treatment
    • Exceptions
    • The three-year holding period
    • Waivers and deferrals
    • Look-through rules
    • Anti-avoidance rules
    • Other provisions
  3. Tax reporting challenges involving carried interests
  4. Differences between federal and state treatment of carried interests

Benefits

The panel will discuss these and other relevant topics:

  • General treatment of carried interest holders under the regulations
  • Exceptions to this general treatment, such as where a carried interest holder also invests capital in their fund
  • Transfers of carried interest--in particular, gain recognition on transfers to related parties
  • Treatment of seed investors and other persons who may indirectly participate in the carried interest (by virtue of invested capital rather than performing services)
  • Potential differences between state and federal tax treatment of carried interest

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Determine the proper tax reporting treatment of carried interests for fund managers and the impact of the proposed rules on carried interest reporting
  • Discern differences in the tax treatment of carried interest between the federal government and various states
  • Identify potential defects in profits interest grants that could be taxable as ordinary income
  • Recognize the impact of existing carried interests on other investors

  • 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, legal or public firm experience at mid-level within the organization, involved in sophisticated tax planning and reporting; supervisory authority over other attorneys/preparers/accountants. Knowledge and understanding of partnership and other pass-through entities, IRC 1061, 1231; familiarity with tax planning for hedge funds, private equity, and real estate professionals.

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).