Private Investment Funds and Tax Reform
Carried Interest, QBI and Interest Deductions, Sale of Partnership Interests, Computation of UBTI, and More
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide private equity counsel with a working knowledge of the critical provisions of tax reform for the private investment fund industry.
Outline
- Tax reform 2017: background and timeline for implementation
- Carried interest
- 20% deduction on qualified business income
- Gain on sale of an interest in a partnership engaged in a U.S. trade or business treated as ECI
- UBTI computed separately for each trade or business activity
- Changes to interest deductibility: implications not only for portfolio companies and leveraged "blocker" corporations
- Limitation on excess businesses' losses for taxpayers other than corporations
- Expansion of controlled foreign corporation rules
Benefits
The panel will review these and other highly relevant issues:
- How does the 20% qualified business income deduction work and what constitutes "qualified business income"?
- How might the new carried interest provisions affect fund sponsors and the alignment of interests between fund sponsors and fund investors?
- How are foreign investors and tax-exempt investors in private equity funds impacted by the new tax law?
- How might changes in interest deductibility and the new corporate tax rate affect fund and investment structures?
Faculty
Jace E. Clegg
Partner
Gunderson Dettmer Stough Villeneuve Franklin & Hachigian
Mr. Clegg's practice encompasses all areas of general corporate and partnership income taxation as well as the... | Read More
Mr. Clegg's practice encompasses all areas of general corporate and partnership income taxation as well as the taxation of mergers and acquisitions (both domestic and cross-border). He is broadly experienced with partnership taxation and has worked on numerous matters involving structuring tax efficient commercial and transactional structures for our corporate clients. Additionally, Mr. Clegg's practice focuses on the formation and general representation of venture capital and private equity funds and related entities.
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Brian D. Huber
Partner
Gunderson Dettmer Stough Villeneuve Franklin & Hachigian
Mr. Huber supports venture capital and growth equity fund managers on all aspects of the fund lifecycle. He has... | Read More
Mr. Huber supports venture capital and growth equity fund managers on all aspects of the fund lifecycle. He has significant experience advising fund managers on issues related to fundraising, GP management, and economics, including the tax and structuring aspects of fund formations and investments globally. He helps clients navigate complex matters in the evolving legal and regulatory landscape, such as the impact of recent tax reform on investment and organizational decision-making. He also has significant experience advising fund managers and investors in connection with secondary purchases and sales of fund interests.
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