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Product ID: 407017EAU
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Advanced Tax Strategies in Structuring Private Investment Funds: Balancing Competing Interests

OnDemand Webinar (76 minutes)

Gain an understanding on critical fund structuring considerations in light of recent tax laws in order to better advise your clients.Recent changes in the tax law require careful review of private investment fund and general partner structures, as well as consideration of potential amendments to the existing fund documentation to achieve tax efficiency. Many tax practitioners may not be aware of essential planning techniques to avoid tax pitfalls. This topic review such factors as type of investor, type of fund and location of fund and general partner tax planning considerations. Fund professionals and advisers will benefit from this topic's general overview of the typical structures and a deeper dive into current tax issues, such as the impact of the CARES Act, proposed carried interest regulations and potential changes to the tax rates. This information is critical for the professionals trying to stay ahead of the changes and better serve their clients.


Olga A. Loy, Winston & Strawn LLP


Tax Structuring Considerations - Fund Level

• Choice of Entity

• Choice of Jurisdiction

• Advanced Structures: Parallel Funds, Master-Feeder Funds, Use of Blockers

Tax Structuring Considerations - Investor Level

• Tax Issues for U.S. Taxable Investors (Including Impact of Tax Reform)

• Tax Issues for U.S. Tax-Exempt Investors - UBTI and Structuring Solutions

• Tax Issues for Non-U.S. Investors - ECI and Structuring Solutions

Tax Structuring Considerations - General Partner and Fund Manager Level

• Carried Interest and Management Fee Structuring Considerations

• Tax Implications of the Grant of Profits Interests, Vesting Restrictions, Adding New Principals and Other Common Manager Arrangements

• Proposed Section 1061 Carried Interest Regulations: Issues and Structuring Solutions