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Year-End Tax Planning for Hedge Funds, Private Equity Funds, Investment Partnerships, and Fund Managers

Note: CLE credit is not offered on this program

Recording of a 110-minute CPE webinar with Q&A

This program is included with the Strafford CPE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
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Conducted on Tuesday, November 23, 2021

Recorded event now available

This course will explain techniques to lessen or defer (or accelerate) taxes paid by hedge funds and private equity funds and investors therein, family offices, and managers. Our panel of veteran fund advisers will discuss carried interest, installment sales, deducting worthless investments, Section 163(j) interest deductions, proposed or actual legislation and other tax considerations of investment partnerships.

Description

Year-end is prime time to do tax planning, especially with significant proposed (enacted?) changes. There have been significant tax changes that impact investment partnership and more may be enacted.

Whether through a hedge fund, private equity fund, family office, or individual investments, there are specific steps partnerships and investors can take to mitigate tax. Treatment of gains and losses on sales is key to deferring, mitigating, or avoiding tax on investments.

A Section 475(f) mark-to-market election exempts trades from wash sale adjustments and the capital loss limitation. Once made, however, and whether beneficial or not, the election remains in effect until revoked.

At the forefront of tax concerns for these partnerships and partners is the treatment of carried interest. Currently, Section 1061 requires applicable partnership interests (APIs) to meet a three-year holding requirement to be eligible for long-term capital gains treatment on certain sales.

Tax practitioners working with entities and managers handling investments need to understand the elections, deductions, and planning strategies available to lessen their respective tax burdens.

Listen as our panel of tax experts describes the strategies available to mitigate taxes paid by investment partnerships, their investors and their fund managers.

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Outline

  1. Investment partnerships and fund managers
  2. Section 1061 carried interest
  3. Section 475(f) mark-to-market election
  4. Wash sales
  5. Constructive sales
  6. Installment sales
  7. REITs
  8. Trader vs. investor status
  9. Section 1256 gains and losses
  10. Worthless securities
  11. Deducting business interest
  12. State tax considerations
  13. Alternative alternative tax planning
  14. Pass-through entity taxes

Benefits

The panel will review these and other critical issues:

  • Critical differences between trader and investor status
  • Year-end tax planning to do before the end of 2021 and possibly after
  • Considerations before making a Section 475(f) mark-to-market election
  • Proposed changes to carried interest regulations

Faculty

Cagnetta, Richard
Richard A. Cagnetta, CPA
Tax Principal
Untracht Early

Mr. Cagnetta focuses on providing tax advisory and compliance services to the firm’s asset management clients...  |  Read More

Dubnoff, Neil
Neil A. Dubnoff
Partner
Kleinberg Kaplan Wolff & Cohen

Mr. Dubnoff focuses his practice on the tax aspects of onshore and offshore investment funds and their investment...  |  Read More