Agenda

June 22, 2021

9:00 – 9:15AM ET

Welcome and Chairperson’s Opening Remarks

George Teixeira, Partner

Anchin 

9:15 – 10:00AM ET

Planning Around Prospective Tax Changes and the Latest Fund Tax Issues

  • Understand Biden’s tax ideas and priorities to plan ahead
  • Discuss structuring for new regulations, increased tax rates, and potential tax opportunities
  • Review choice of entity and which business structure will be the best fit under the Biden administration
  • Assess the tax implications from the second stimulus package, an extension of CARES Act provisions, and other tax proposals

 

Tony Tuths, Tax Principal, Alternative Investments

KPMG

 

Jean-Paul Schwarz, Principal

Citrin Cooperman

10:00 – 10:15AM ET
Break

10:15 – 11:00AM ET

State Tax Issues for Investment Management Companies and Funds

  • Learn how management companies across the nation are handling allocation and filing requirements due to employees working remotely across state lines
  • Better understand how income is sourced to a state or city
  • Explore state level mechanisms that New Jersey, Connecticut and other states have created to bypass SALT deduction limitations
  • Discuss other state tax issues for funds

 

Isaac Hefez, Senior Manager, State and Local Tax

KPMG

 

Leighanne Scott, Member

Caplin & Drysdale

 

Nicholas Passantino, Tax Director

PwC

11:00 – 11:15AM ET
Break

11:15 – 12:00PM ET

Discuss Structures That Work; Blockers Under the TCJA, the CARES Act and Biden’s Proposed Changes

  • Dive into interest expense deduction limitations, focusing on real estate and NOL limitations
  • Examine the latest on fund structuring
  • Strike the optimal ratio of debt to equity for effective blockers
  • Explore blockers for foreign investors, tax-exempt investors, and taxable investors

  

Jill Darrow, Partner

Katten Muchin Rosenman

 

Philip Gross, Member

Kleinberg, Kaplan, Wolff & Cohen

12:00 – 1:00PM ET
Working Lunch

Working Lunch:  Enter the Networking Lobby, choose a roundtable topic that interests you, double-click an open seat and join your peers for a lively small-group discussion. Make sure to turn your camera on and easily switch between virtual tables to meet speakers, grow your network, and say hello to familiar faces.

1:00 – 1:45PM ET

Consequences of Recent Tax Changes for Investors and Portfolio Companies

  • Learn the applications of CARES Act changes to 2020 tax returns and future returns
  • Maximize the temporary relief from interest expense deductions and NOL limitations and carryback rules and considerations for amended returns versus tentative refund claims
  • Apply the excess business loss limitation rules effectively
  • Understand the specifics of taking the qualified improvement property bonus depreciation through amended returns
  • Address the impact to partnerships and investors when AARs are filed under the centralized partnership audit regime

 

David Untracht, Senior Principal

Untracht Early

 

Miri Abrams Forster, Principal and Tax Controversy Co-Leader 

Eisner Amper 

1:45 – 2:00PM ET
Break

2:00 – 2:45PM ET

Examine Key, Recently Required Disclosures on Form 1065 and Schedule K-1

  • Understand the conversion of GAAP capital accounts to tax basis capital accounts, mandatory for 2020 filings
  • Analyze the latest on the centralized partnership audit regime
  • Scrutinize reporting requirements for qualified opportunity funds to take the best advantage
  • Learn about 2021 tax filing season tax return issues confronted and positions taken

 

Laura Ross, Partner

Eisner Amper

 

Ryan Schneider, Partner - Asset Management Tax

PwC

 

David Helprin, Managing Director

SS&C Technologies

2:45 – 3:00PM ET
Break

3:00 – 3:45PM ET

Get Granular with Carried Interests

  • Understand the tax consequences between capital interest versus carried interest
  • Discuss segregation of gains and losses under the aggregation method as well as disclosure of gains and losses
  • Address Section 1231 gains and Section 1256 gains
  • Examine tax planning under the final regulations

 

Mark Leeds, Partner

Mayer Brown

 

Edward Dougherty, National Managing Partner, Investment Management Tax; National Hedge Fund Leader

Deloitte

 

David Benz, Former Tax Partner

Crowe

3:45 – 4:00PM ET
Break

4:00 – 4:45PM ET

Focus on Tax Disclosures in Private Placement Memorandums

  • Understand the effects of business versus trader activities on foreign investors and domestic investors
  • Identify activities that require special disclosures in loan origination, litigation claims, and life settlement funds and what those disclosures are
  • Address foreign withholding and reporting as well as passive foreign investment company (PFIC) and controlled foreign corporation (CFC) issues
  • Discuss the tax implications of various elections that may be made

 

James Cofer, Partner

Seward & Kissel

4:45PM ET

Day One Closing Comments

George Teixeira, Partner

Anchin 

June 23, 2021

9:00 – 9:15AM ET

Day Two Opening Remarks

George Teixeira, Partner

Anchin 

9:15 – 10:00AM ET

Keynote Address: Legislative Update

Lee Sheppard, Contributing Editor

Tax Analysts’ Tax Notes

10:00 – 10:15AM ET
Break

10:15 – 11:00AM ET

Planning Under the Subpart F and GILTI Rules Applicable to US Shareholders of Controlled Foreign Corporations

  • Address CFC rules and the impact of Subpart F on income deferment
  • Understand Subpart F income regulations and GILTI inclusions
  • Avoid attribution from foreign persons and tax traps
  • Discuss CFC regulations redefining US shareholders

 

Maury Cartine, Partner

Marcum

 

Michael Miller, Partner

Roberts & Holland

11:00 – 11:15AM ET
Break

11:15 – 12:00PM ET

Management Fee Waivers, Carried Interest Waivers, Tax Basis and Distribution in-Kind Rules That Effect Investment Managers

  • Explore consequences of waiving management fees for a future profits interest, and of waiving a carried interest on assets sold and not held for more than three years
  • Discover serious mistakes highlighted by tax basis capital accounts
  • Consider opportunities and pitfalls surrounding allocation of recourse and non-recourse liabilities, including rules governing “bottom dollar guarantees”
  • Explore opportunities afforded by in-kind distributions in connection with public offerings and SPAC transactions

 

Amanda Nussbaum, Partner

Proskauer Rose

 

Michael Spiro, Partner

Finn Dixon & Herling

12:00 – 1:00PM ET
Working Lunch

Working Lunch: Enter the Networking Lobby, choose a roundtable topic that interests you, double-click an open seat and join your peers for a lively small-group discussion. Make sure to turn your camera on and easily switch between virtual tables to meet speakers, grow your network, and say hello to familiar faces

1:00 – 1:45PM ET

Revisit Hedge Fund Tax Issues and What Is Working Now

  • Get insights to avoid pitfalls in constructive sales, wash sales, straddles and holding periods
  • Master special allocations of gains “stuffing” or filling-up methodologies as well as losses
  • Understand the characterization of swap contract gains and losses for appropriate treatment
  • Distinguish tax treatment of investments under Section 1256 versus Section 988

 

Mark Fichtenbaum, CPA, JD, LLM, President

MF Consulting

Clinical Assistant Professor

Pace University

 

Lisa Head, CPA, Partner-In-Charge

Weaver

1:45 – 2:00PM ET
Break

2:00 – 2:45PM ET

Reap the Benefits and Avoid the Perils of Passive Foreign Investment Companies (PFICs)

  •  Learn about advantages of PFICs and the recent regulations affecting them, for better planning
  • Better understand the functionality of PFICs and how US persons are taxed on PFIC income
  • Discover elections available to mitigate adverse tax consequences and how qualified electing funds (QEFs) are taxed
  • Prepare for the pitfalls as well as the benefits of investing in a PFIC

 

Steven Bortnick, Partner

Troutman Pepper Hamilton Sanders

 

Seda Livian, Partner

EY

2:45 – 3:00PM ET
Break

3:00 – 3:45PM ET

Get up to Speed on New Developments in Taxation of Alternative Investments

  • Learn about tax advantages of investing in the secondaries market
  • Better understand special purpose acquisition companies (SPACs) and their key tax consequences
  • Discover new developments in cryptocurrency best practices and tax treatment
  • Get insight to the latest Wall Street tax products

 

Mindi Lowy, Tax Partner – Alternative Investments Tax Practice

PwC

 

Shehan Chandrasekera, Partner

JAGArgueta CPAs

Head of Tax Strategy

CoinTracker

 

Ron Nardini, Partner

Akin Gump

3:45 – 4:00PM ET
Break

4:00 – 4:45PM ET

Key Tax Provisions of Fund Operating Agreements and Subscription Agreements

  • Analyze operating agreement essentials, such as stuffing, the drafting of tax provisions, targeted allocations, and other essential components
  • Discover potential opportunities and avoid pitfalls by examining waterfall distribution models and schedules for allocating capital gains to limited and general partners
  • Understand targeted accounting and more detailed provisions

 

Russell Pinilis, Partner

Willkie Farr & Gallagher

4:45PM

Final Remarks and Conference Concludes

George Teixeira, Partner

Anchin