EST2215. Estate Planning for Private Equity and Opportunity Zone Funds

To submit a question or participate in polling, click the link above. Private Equity and Opportunity Zone fund managers typically receive a special equity interest in the fund commonly referred to as a "carried" or "profits interest", as incentive compensation for managing the fund. Successful managers that earn a return exceeding the fund's hurdle rate often receive 20% of the fund's profits creating significant value to the fund manager over the life of the fund. This session will explore estate planning opportunities for the Manager's carried interest comparing different approaches and highlighting income tax and gift tax technical issues including application of IRC Section 2701. In addition, we will discuss valuation of the Manager's carried interest for gift tax purposes including significant factors impacting the current value and potential future value of a successful fund.

Learning Objectives:

• Recognize various estate planning approaches for fund managers along with knowledge of the primary benefits and disadvantages of each approach.
• Recall the key valuation drivers of a carried interest for gift tax purposes.