Last Year's 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
  • Examine recent exam trends to better prepare for increased scrutiny in key areas

 

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

 

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

 

David Benz, Former Tax Partner

Crowe

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

 

Sajjad Qamar, Senior Director 

RSM US 

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

 

George Teixeira, Partner

Anchin 

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 considerations 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

 

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