BNA Webinar featuring David C. Jacobson – Transfer Tax Planning with Carried Interests in Hedge and Private Equity Funds
“What makes carried interest a popular gifting vehicle is that it typically has a relatively low value initially due to its speculative nature. But, as a hedge fund’s returns grow, so does that value of the carried interest”, Boom in Trusts Passing Carried Interest to Heirs, Wall Street Journal, February 18, 2014. This timely program will illustrate effective wealth transfer strategies for private equity and hedge fund principals. We will navigate the pitfalls of Section 2701 of the IRC. We will analyze “vertical slice” planning and the non-vertical alternatives including the use of derivative instruments. The program will address the real world challenges of Vesting, Capital Calls and Clawbacks. And we will focus on the key valuation considerations and methodologies of fund interests, which are essential for tax-efficient transfer techniques.