Final Section 1061 Carried Interest Regulations
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide fund managers and advisers with a practical guide to the challenges and planning opportunities found in the final regulations and the proposed tax changes to the carried interest rules.
Outline
- Background
- Carried interest treatment in the final regulations
- APIs defined
- Capital interest exception
- The three-year holding period
- Capital interests acquired with loan proceeds
- Look-through rules
- Anti-avoidance rules
- Related party transfers
- Other provisions
- Tax reporting challenges involving carried interests
- Potential federal and state changes
Benefits
The panel will review these and other relevant topics:
- Overview of Section 1061 and the final regulations issued January 2021
- Capital interest exception
- 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 invested capital rather than performing services)
- Potential differences between state and federal tax treatment of carried interest
Faculty
Victoria Glover
Partner
Deloitte Tax
Ms. Glover is a partner in Washington National Tax in both the Passthroughs Group and Tax Policy Group. She specializes... | Read More
Ms. Glover is a partner in Washington National Tax in both the Passthroughs Group and Tax Policy Group. She specializes in partnership taxation and provides insights on U.S. tax policy developments. Before returning to Deloitte, Ms. Glover served as the majority tax advisor for the US House Committee on Ways and Means. As majority tax advisor, she was responsible for developing and implementing changes to the tax code with respect to domestic businesses, including partnerships, in the Tax Cuts and Jobs Act of 2017. Ms. Glover is a frequent speaker at events sponsored by Deloitte and notable tax conferences. She also co-authors the online treatise, Federal Income Taxation of Passive Activities.
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Irina Kimelfeld
Partner
Eisner Advisory Group
Ms. Kimelfeld is a Tax Partner and a member of the Financial Services Group. With over 25 years of experience, she... | Read More
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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