Overview
This comprehensive webinar will update you on the latest rules and regulations impacting hedge funds in the aftermath of the Tax Cuts and Jobs Act. You’ll learn about recent IRS rulings, guidelines for partnerships, carried interest, liability, and other matters that are essential for investors.
AGENDA HIGHLIGHTS
• Carried Interest
– Section 1061 of the Code
– Applicable partnership interest
– Applicable trade or business
– Specified assets
– Exceptions to API treatment
– Four requirements
– Transfers to related persons
– Open issues on 1061(d)
– Other provisions
• Liability Sharing & Reporting Rules
– Section 752
– Application of rules
– Treas. Reg. 1.752-2(k)
– Commercially reasonable expectation of payment
– Relevant factors
– Balance sheets
– Income and cash flow statements
– Credit reports
– Projected future financial results
– Hedge fund general partner
– Practical impact
– Potential solutions
– Reporting requirements and latest guidance
• LP Audit Activity Update
– Self-employment tax
– IRS position
– Audits
• Investment Interest Expense
– Proposed regulations
• CARES Act
– Temporary code revisions
• Looking Ahead
– Biden tax proposals
– TCJA Act on fund restructuring
– State and Local Taxes (SALT)
LEARNING OBJECTIVE To update Accounting and Financial Professionals on the latest tax issues related to hedge funds.
PREREQUISITE None. ADVANCE PREPARATION None. PROGRAM LEVEL Intermediate.
NASBA FIELD OF STUDY Taxes. DELIVERY METHOD Group Internet-Based.
Speakers
SPEAKERS
James Cofer, Partner, Seward & Kissel
Roger Lorence, Tax Lawyer, Consultant
Workshop
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