Wealth Planning with Hedge Fund and Private Equity Fund Interests and Related Section 2701 Issues (Portfolio 875)
This Portfolio, 6875 T.M., U.S. Income Tax Treaties — Benefits Provided by a Country to Its Own Residents and Citizens, covers the benefits granted under a bilateral income tax treaty.
Tax Management Portfolio No. 875, Wealth Planning with Hedge Fund and Private Equity Fund Interests and Related Section 2701 Issues, offers an overview of the fundamentals of estate planning with carried interests and a discussion of cutting-edge issues in this area. The Portfolio first provides the reader with a general overview on private equity funds, hedge funds, carried interests, fund structures, and securities law. The Portfolio explores the various estate planning reasons for making transfers of carried interests, and the tax consequences that could result from such transfers. Specifically, the Portfolio closely examines potential pitfalls that could arise under §2701, and details planning approaches to avoid §2701 tax consequences. The Portfolio discusses other transfer tax issues and describes general estate planning techniques in the context of these funds, as well. Finally, the Portfolio addresses special topics in the context of funds, including: buy-sell agreements, deferred compensation planning, international planning considerations, and income tax considerations.
While this Portfolio provides a general overview on private equity funds, hedge funds, and §2701, for more detailed discussions, see 735 T.M., Private Equity Funds (U.S. Income); 736 T.M., Hedge Funds (U.S. Income); and 835 T.M., Transfers of Interests in Family Entities Under Chapter 14: Sections 2701, 2703 and 2704, respectively.
This Portfolio may be cited as Angkatavanich, Stein & Haave, 875 T.M., Wealth Planning with Hedge Fund and Private Equity Fund Interests and Related Section 2701 Issues.
Table of Contents
I. Overview of Fund Structures and Non-Transfer Tax Issues
II. Transfers of Carried Interests
III. Deemed Gift Pitfalls Under §2701
IV. Transfer Tax Issues Other than §2701
V. Estate Planning Techniques for Transfers of Fund Interests
VI. Buy-Sell Agreements and Succession Planning
VII. Deferred Compensation Planning
VIII. International Planning for the Global Fund Principal
IX. Income Tax Considerations
Goldman , Sachs & Co.
Withers Bergman LLP
Principal, National Tax Department
Ernst & Young