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Transfer Tax Planning with Carried Interests in Hedge and Private Equity Funds

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DESCRIPTION

“What makes carried interest a popular gifting vehicle is that it typically has a relatively low value initially due to its speculative nature. But, as a hedge fund's returns grow, so does that value of the carried interest”, Boom in Trusts Passing Carried Interest to Heirs, Wall Street Journal, February 18, 2014.  

This timely program will illustrate effective wealth transfer strategies for private equity and hedge fund principals.  We will navigate the pitfalls of Section 2701 of the IRC.  We will analyze “vertical slice” planning and the non-vertical alternatives including the use of derivative instruments.  The program will address the real world challenges of Vesting, Capital Calls and Clawbacks.  And we will focus on the key valuation considerations and methodologies of fund interests, which are essential for tax-efficient transfer techniques.

Educational Objectives
• Navigate the deemed gift rules of Section 2701
• Master vertical slice transfer planning 
• Discover the non-vertical alternatives
• Understand how to value carried interests for gift tax purposes 

Who would benefit most from attending this program?
Private investment fund managers and their advisors, attorneys, accountants, financial and estate planners and other professionals who advise clients on estate planning, trust planning and wealth management matters.
Promotion Codes available only for authorized customers. Each code may only be used once.

SPEAKERS

DAVID C. JACOBSON, COUNSEL, MELTZER LIPPE GOLDSTEIN & BREITSTONE, LLP

David C. Jacobson is Counsel in the Tax and Trusts & Estates Departments of Meltzer Lippe Goldstein & Breitstone, LLP in New York.  Prior to joining Meltzer Lippe, David led the national wealth planning effort for Capital One Private Wealth Management, where he provided tax and trust and estate planning advice to families throughout the United States.  He previously held a similar position at UBS Private Wealth Management in New York.  David began his career as an attorney with the law firm Carter, Ledyard & Milburn, in Manhattan.  David is a member of the Asset Protection Planning and the Income and Transfer Tax Planning Committees of the American Bar Association.  He is also a member of the Planned Giving Advisory Committee of the New York Museum of Modern Art.  David received his LL.M. in Taxation from Georgetown University Law Center in 1992, his J.D. from the University of Miami School of Law in 1991, and his B.A. from the University of Oklahoma in 1988.  He is admitted to practice law in Florida and New York. 


DAVID J. THOMPSON, MANAGER, EMPIRE VALUATION CONSULTANTS, LLC

David J. Thompson is a Manager with Empire Valuation Consultants, LLC, where he has focused on the valuation of private equity and hedge fund management companies and general partner entities for over a decade.   He is a graduate of the Australian Graduate School of Management, MBA, Finance, the Duke Fuqua School of Business, MBA, Finance, General - International Exchange Program, and the University at Buffalo, BA, Mathematics.  Mr. Thompson is a Chartered Financial Analyst (CFA), and has valued a wide variety of publicly and privately-held companies for a variety of purposes including estate and gift tax reporting.  He has extensive experience in valuing private equity and hedge fund company interests.