Partner Profits Interests: IRS Safe Harbor, Migrating From Employee to Partner, Ensuring Capital Gains Treatment
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will discuss the effects of granting, vesting, and selling profits interests in partnerships along with the benefits and burdens of awarding these equity rights. Our panelists will explain the details of these transfers for partnership advisers, members, and professionals employing or considering this tax-effective method of transfering partnership interests.
Outline
- Profits interests: an overview
- Capital vs. profits interests
- IRS safe harbor requirements
- Granting
- Vesting
- Selling
- Section 1061
- Other considerations
Benefits
The panel will cover these and other vital issues:
- The effects of granting a profits interests on the partnership
- The effects of granting a profits interests on the partner
- Granting profits interests with vesting requirements
- Making a protective 83(b) election
- Meeting the IRS safe harbor requirements for profits interests
- Ensuring capital gains treatment at the disposition
Faculty
Michael Hirschfeld
Managing Director
Andersen Tax
Mr. Hirschfeld focuses on international, partnership, corporate, and real estate tax planning and compliance. He has... | Read More
Mr. Hirschfeld focuses on international, partnership, corporate, and real estate tax planning and compliance. He has over 40 years of experience with tax issues that affect partnerships/LLCs, REITs, cross-border investing, real estate acquisition, finance and investment, private equity, distressed debt, mergers and acquisitions, pharmaceutical, energy, and clean technology clients. Mr. Hirschfeld was Chair of the Tax Section of the American Bar Association and a member of the Executive Committee of the Tax Section of the New York State Bar Association. Currently, he is the President of the Board at American Tax Policy Institute and an officer in the ABA Section of Real Property, Trust and Estate Law. Before Andersen, Mr. Hirschfeld was a distinguished practitioner in residence at Cornell Law School and a retired law partner with an international law firm.
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Joseph E. Hunt, IV, J.D., LL.M.
Member
Morse Barnes-Brown & Pendleton
Mr. Hunt has eight years of advisory and legal experience, counseling startup, emerging, and middle-market companies... | Read More
Mr. Hunt has eight years of advisory and legal experience, counseling startup, emerging, and middle-market companies throughout all stages of the entity life cycle, including formation, tax structuring, issuing equity, venture capital financing, and mergers and acquisitions. His clients span a variety of different industries at all stages of corporate development, with a particular focus in serving technology and life sciences startup companies. Mr. Hunt is a member of the adjunct faculty at Boston University School of Law where he teaches in the Graduate Tax Program.
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