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Earn 13.5 CPE Tax Credits

T H E 9TH A N N U A L

PRIVATE INVESTMENT FUNDS TAX MASTER CLASS The Industry’s Most Complete and Concise Tax Event for both Private Equity Funds and Hedge Funds

May 22-23, 2018

|

The Princeton Club

|

New York City

How will new tax legislation affect your fund’s planning going forward? Hear some of the industry’s most renowned tax experts discuss everything you must know about the Tax Cuts and Jobs Act. Whether your focus is on hedge fund tax or private equity tax, we’ve got you covered with concurrent tracks!

G O L D S PONS O RS

S ILVER SPONSOR

BRONZE SPONSOR

To R e g i s t e r : C a l l 8 0 0 - 2 8 0 - 8 4 4 0 o r v i s i t u s a t e v e n t s . f r a l l c . c o m / b 1 0 7 5 v 3 m s 4 . 1 7. 1 8


THE TAX LANDSCAPE HAS CHANGED SUBSTANTIALLY, MAKE CERTAIN THAT YOUR FUND HAS THE MOST EFFECTIVE, COST-EFFICIENT PLAN IN PLACE! It’s true, the Tax Cuts and Jobs Act is the most significant tax legislation to come out in decades, and there are multiple provisions that will greatly impact the private fund industry. Unless you really dig in and get a solid understanding of it all, you’re not going to be able to accurately answer to your investors, and/or potential investors, on how you’re implementing tax reform. With a stellar line-up of some of the industry’s most well-renowned tax experts, you’ll get indepth analysis and practical application on all the major provisions from the new Act at this very important event. Whether you’re from a private equity fund, a hedge fund, or you work with either, you’ll get cutting-edge insight on tax planning strategies in this new era. Register today! Call 800.280.8440 or online at events.frallc.com/b1075. Sincerely, Erin Busch, Conference Director FINANCIAL RESEARCH ASSOCIATES

WHO SHOULD ATTEND? From Hedge Funds and Private Equity Funds: • Chief Financial Officers • Controllers • Tax Managers/Directors • In-house counsel This conference is also a great opportunity for: • Lawyers • Accountants • Consultants • Advisors

TOP REASONS TO ATTEND • Completely understand how the new tax bill affects your fund’s tax planning strategies • Learn how to best address the many international tax issues, both inbound and outbound – from GILTI, BEAT CFCs and repatriation income to inbound blockers and ECI • Be aware of new tax traps that have surfaced in-light-of the new legislation • Develop new and innovative strategies that you can use to increase your fund’s returns in this increasingly complex environment • Hear Keynote speaker Lee Sheppard’s latest thoughts on new and pending tax legislation • Grow your network of high-level private equity and hedge fund tax professionals • Earn up to 13.5 CPE Tax Credits

GET ANSWERS TO THESE QUESTIONS • How have carried interest and passthrough deductions changed? • What is, and what is not, qualified business income and how is it calculated? • What entity/business structure is the best for your needs in this new era? • How will interest deduction limitations affect your deal structuring? • What are the best ways to plan for blockers? • How will tax modeling change prior to making investments? • What kind of guidance has the IRS offered on cryptocurrency investments? • How will interest limitations affect portfolio companies? • Will it be necessary to dramatically change compensation structures for GPs and management companies?


FULL CONFERENCE SCHEDULE AT A GLANCE All attendees will have access to either track and are free to migrate between the two at any time

HEDGE FUND SESSIONS

PRIVATE EQUITY SESSIONS

Day 1

Day 1

9:10 – 10:00

Hedge Fund Tax and Regulatory Update

9:10 – 10:00

Private Equity Tax and Regulatory Update

10:00 – 11:00

How Carried Interest and Pass-Through

10:00 – 11:00

Deal Structuring in a New Tax Era

11:20 – 12:10

Keynote Address – Lee Sheppard

1:10 – 2:00

Compensation Structures for GPs and Management Companies

2:00 – 2:50

Choice of Entity – What Business Structure is the Best Fit Under the New Legislation?

3:10 – 4:00

Fund and Portfolio Company Operations in Light of the New Tax Act

4:00 – 5:00

Tax Considerations for Investing in U.S. Real Estate and Real Estate Related Assets

Deduction Rules Have Changed 11:20 – 12:10

Keynote Address – Lee Sheppard

1:10 – 2:00

Rules Impacting Investor Funds

2:00 – 2:50

C-Corporations, Business Interest and the International Rules

3:10 – 4:00

International Rules in the New Tax Laws – How are Hedge Funds Affected?

4:00 – 5:00

Effective Implementation of Partnership Audit Rules for Hedge Funds Day 2

Day 2

9:10 – 10:00

State and Local Tax Update for Hedge Funds

9:10 – 10:00

Managing Tax Implications of Foreign Investments Part 1 – Subpart F Income

10:00 – 10:50

Effectively Handling Tax Issues with Foreign Investors and Foreign Funds

10:00 – 10:50

11:10 – 12:00

Taxation and Reporting of Debt and Lending Instruments

Managing Tax Implications of Foreign Investments Part 2 – Other Major Issues

11:10 – 12:00

Working Through Tax Implications of Foreign Taxes and Withholding

Interactive Forum Addressing Private Equity’s Most Pressing Issues

1:10 – 2:00

Tax Implications for Derivatives and other Complex Investments

Tax Considerations for Foreign Investors and Investments

2:10 – 3:00

State and Local Tax Update for Private Equity Funds

3:00 – 4:00

Effective Implementation of Partnership Audit Rules for Private Equity Funds

1:00 – 2:00

2:20 – 3:10

3:10 – 4:00

Taxation of Cryptocurrencies


DAY ONE: Tuesday, May 22, 2018 HEDGE FUND TAX 8:00

9:00

9:10

PRIVATE EQUITY TAX

Registration and Continental Breakfast

Chairperson’s Opening Remarks

Chairperson’s Opening Remarks

»» TBD

»» Kenneth DeGraw, Partner WITHUM

Hedge Fund Tax and Regulatory Update:

Private Equity Tax and Regulatory Update:

An Overview of the Tax Cuts and Jobs Act

An Overview of the Tax Cuts and Jobs Act

and Other New Developments

and Other New Developments

The 2017 Tax Act contains major provisions impacting the hedge fund industry. Before we rollup-our-sleeves and get into the details, experts on the new law will provide an overview of what we know so far

The 2017 Tax Act contains major provisions impacting the private equity fund industry. Hear the highlights of the new tax laws and their impact on private equity funds

»» Philip S. Gross, Member KLEINBERG, K APL AN, WOLFF, COHEN

10:00

How Carried Interest and Pass-Through

Private Equity Deal Structuring in a New

Deduction Rules Have Changed

Tax Era

• Do they apply to pre-2018 unrealized? • Special gain allocations impacted • Is a fee structure better than an allocation structure? • Which management entities in a fee structure might qualify for deduction? • Any new planning around carried interest rules • Effect of pass-through deductions on fund investment

• Deal structuring in general with limitations on interest deduction and immediate depreciation • How will tax modeling change prior to making investments? • Debt and leveraging considerations • Pass-through deductions and qualified business income »» Sara Zablotney, Partner KIRKL AND & ELLIS LLP

»» Mark Leeds, Partner MAYER BROWN LLP 11:00

11:20

Refreshment Break

Keynote Address: What “Tax Reform” Means for Private Investment Funds »» Lee Sheppard, Contributing Editor TA X ANALYSTS’ TA X NOTES

12:10

1:10

Lunch And Networking

Rules Impacting Investor Funds

Compensation Structures for GPs and

• Investment expense limitations • A new look at investor/trader status; what is an investor fund • Ways to restructure management fees • Is a PFIC a solution?

Management Companies

»» Alan J. Speer, CPA, Chief Financial Officer BIENVILLE CAPITAL

»» Michael P. Spiro, Partner FINN DIXON & HERLING LLP

»» Amanda H. Nussbaum, Partner PROSK AUER

To Register: Call 800-280-8440 or visit us at www.frallc.com

• • • •

Impact of new legislation Carried interest arrangements Incentive allocations Management fees and allocations


HEDGE FUND TAX 2:00

C-Corporations, Business Interest and the

Choice of Entity – What Business Structure

International Rules

is the Best Fit Under the New Legislation?

• Should financial service entities change to a C or S corporate structure? • Interest rule as applied to trader funds • Blocker corporations

We’ll analyze the following entities and see how, under the new tax bill, one might be a better option for you

»» Seda Livian, Partner ERNST & YOUNG

• C corporation • S corporation • Partnerships

»» Jill E. Darrow, Partner K AT TEN MUCHIN ROSENMAN

»» R. Eric Emrich, CPA, Chief Financial Officer INDEPENDENCE CAPITAL PARTNERS, LLC

2:50

3:10

PRIVATE EQUITY TAX

Refreshment Break

International Rules in the New Tax Laws –

Fund and Portfolio Company Operations in

How are Hedge Funds Affected?

Light of the New Tax Act

• • • • •

• Interest limitations as they pertain to the portfolio company • Expensing of assets • Complications of reporting excess business income

GILTI BEAT Identifying CFCs Repatriation income Interest expense in blockers

»» Michele Gibbs Itri, Partner TANNENBAUM HELPERN SYRACUSE & HIRSCHTRIT T LLP

»» Ron G. Nardini, Partner AKIN GUMP »» Michael B. Shulman, Partner SHEARMAN & STERLING

»» Moshe Metzger, Partner RSM US LLP

4:00

Effective Implementation of Partnership

Tax Considerations for Investing in U.S.

Audit Rules for Hedge Funds

Real Estate and Real Estate Related Assets

• Partnership representative designation • Annual election • Tax accounting for partnership audit adjustments • What should be in fund documents? • Changing partnership agreements – how can this be done?

• U.S. tax considerations for non-U.S. and U.S. taxexempt investors investing in U.S. real estate • Structures used by to mitigate U.S. tax leakage for non-U.S. and U.S. tax-exempt investors • Use of REITS »» Jeffrey Uffner, Partner STROOCK

»» Miri Abrams Forster, Principal KPMG 5:00

Cocktail Reception

To Register: Call 800-280-8440 or visit us at www.frallc.com


DAY TWO: Wednesday, May 23, 2018 HEDGE FUND TAX

PRIVATE EQUITY TAX

8:00

9:00

9:10

10:00

Continental Breakfast

Chairperson’s Day One Re-Cap

Chairperson’s Day One Re-Cap

»» TBD

»» Kenneth DeGraw, Partner WITHUM

State and Local Tax Update for Hedge

Managing Tax Implications of Foreign

Funds

Investments Part 1 – Subpart F Income

• Impact of new federal tax laws on state taxes • Various SALT withholding requirements • Structuring conside rations in light of new state tax rules • State market sourcing update • General state tax allocations

• An in-depth look at Global Intangible Low Taxed Income (GILTI) • Section 962 • CFC distributions

Effectively Handling Tax Issues with

Managing Tax Implications of Foreign

Foreign Investors and Foreign Funds

Investments Part 2 – Other Major Issues

• • • • •

• Deemed repatriation • Base Erosion Anti-Abuse Tax • Changes to attribution rules

Best practices for managing ECI Use of blockers, leveraging investments Interest and dividend withholding Loan origination FIRPTA

»» Steven D. Bortnick, Partner PEPPER HAMILTON LLP

»» Puneet Arora, Tax Principal PWC

»» Roger Wise, Tax Partner WILLKIE FARR & GALL AGHER LLP »» Meredith Levy, Partner KIRKL AND & ELLIS LLP 10:50

11:10

Networking Break

Working Through Tax Implications of

Interactive Forum Addressing Private

Foreign Taxes and Withholding

Equity’s Most Pressing Issues

• Treaty analysis – inbound and outbound analysis • Recovering excess withholding tax • A look at the most pressing foreign tax issues – both current and proposed

• Overall state of the private equity industry • Fundraising • What’s on the horizon?

»» Brian Sapadin, Executive Director GLOBE TA X SERVICES

12:00

1:10

»» Phyllis Schwartz, Partner SCHULTE ROTH & ZABEL LLP »» Jason Donner, Chief Financial Officer VERITAS CAPITAL

Lunch and Networking

Taxation and Reporting of Debt and

Tax Considerations for Foreign Investors

Lending Instruments

and Investments

• • • •

• • • •

Debt equity rules after regulation retraction FX impact on debt instruments Direct lending and US trader issues Handling various fees associated with debt instruments

»» Mark Howe, Partner CADWAL ADER To Register: Call 800-280-8440 or visit us at www.frallc.com

Inbound blockers Dealing with interest expense limitations Considerations for ECI Section 1446

»» Adam Tejeda, Partner K&L GATES


HEDGE FUND TAX 2:00

2:10

PRIVATE EQUITY TAX Networking Break

Tax Implications for Derivatives and other

State and Local Tax Update for Private

Complex Investments

Equity Funds

• • • • • •

• Various SALT withholding requirements • Structuring considerations in light of new state tax rules • State market sourcing update • General state tax allocations

Mark-to-market status Section 1260 – constructive ownership rules Credit default swaps Bullet swaps Wash sale/deemed exchange implications Significant and non-significant non-periodic payments

»» Edner Jocelyn, Partner WITHUM

»» Edward Dougherty, Partner DELOIT TE TA X

3:00

Taxation of Cryptocurrencies

Effective Implementation of Partnership

• Understanding blockchain technology and cryptocurrencies • What guidance has the IRS offered on cryptocurrencies? • What are ICOs? • Keeping track of basis

Audit Rules for Private Equity Funds

»» Steve Yardumian, Partner WITHUM 4:00

• Tax representative designation • Annual election • Tax accounting for partnership audit adjustments • What should be in fund documents? • Changing partnership agreements – how can this be done?

Conference Adjourns

To Register: Call 800-280-8440 or visit us at www.frallc.com


VENUE DETAILS

THE CONFERENCE ORGANIZER

The Princeton Club 15 West 43rd Street, New York, NY 10036 212 . 596.1200 If you require overnight accommodation for this conference, please contact any of the following nearby hotels to check their best available corporate rate over this time frame, or consult your local travel agent. Please note that FRA has not negotiated rates with any of these hotels.

Area Hotels: InterContinental Times Square - 212.803.4500 Westin Times Square - 866.837.4183 Millennium Broadway Hotel - 212.768.4400 Hotel Sofitel New York - 212. 354.8844

Financial Research Associates provides the financial community with access to business information and networking opportunities. Of fering highly targeted conferences, FRA is a preferred resource for executives and managers seeking cuttingedge information on the next wave of business opportunities. Please visit w w w.frallc.com for more information on upcoming events.

CPE CREDITS

TEAM DISCOUNTS • Three people will receive 10% off. • Four people will receive 15% off. • Five people or more will receive 20% off. In order to secure a group discount, all delegates must place their registrations at the same time. Group discounts cannot be issued retroactively. For more information, please contact Kathie Eberhard at 704. 341.2439 or keberhard@frallc.com REFUNDS AND CANCELL ATIONS For information regarding refund, complaint and/ or program cancellation policies, please visit our website: w w w.frallc.com/thefineprint.aspx

SPONSORSHIP AND EXHIBIT OPPORTUNITIES Enhance your marketing ef forts through sponsoring a special event or exhibiting your product at this event. We can design custom sponsorship packages tailored to your marketing needs, such as a cocktail reception or a custom-designed networking event. To learn more about sponsorship opportunities, please contact Samantha Rosky at 704. 341.2390 or srosky@frallc.com.

To Register: Call 800-280-8440 or visit us at www.frallc.com

Financial Research Associates is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: w w w.nasbaregistry.org. PROGRAM LEVEL: Intermediate ANTICIPATED CPE CREDITS: 13. 5 RECOMMENDED FIELD(S) OF STUDY: Tax PREREQUISITES: Working knowledge of private equity and/or hedge fund taxation principles ADVANCE PREPARATION: None INSTRUCTIONAL DELIVERY METHOD: Group Live LEARNING OBJECTIVES: upon completing the course, participants will: • Get a better and more thorough understanding of new tax legislation • Learn how to address changes in international tax laws • Structure their funds for better tax efficiency For more information, visit our website: w w w.frallc.com/thefineprint.aspx


SPONSORS Gold Sponsors Elliott Davis ranks among the top 30 CPA firms in the U.S. and was recognized as the #1 firm for revenue growth by Accounting Today in 2015. With sixteen of fices across six states, the firm provides comprehensive assurance, tax and consulting solutions to diverse businesses, organizations and individuals. Our Investment Companies Practice provides a variety of services to a wide range of investment entities, with an emphasis on hedge funds and private equity groups. We are a PCAOB-registered and –inspected firm and have been recognized by HFMWeek and HFAlert.com as one of the leading hedge fund auditing firms in the nation, ranking #10 among the Top 20 auditors of hedge funds managed by SEC-registered investment advisors. Elliott Davis is an independent firm associated with Moore Stephens International Limited, one of the world’s largest CPA firm associations with resources in every major market around the globe. For more information, please visit w w w.elliottdavis. com or contact Renee Ford or Karl Jordan at 423.756.7100. WithumSmith+Brown (Withum), is a full service accounting and consulting firm, with over 40 years of experience in the financial services field, providing audit, tax and consulting services to hedge funds, private equity funds, commodity pools, mortgage bankers, broker-dealers, and regulated investment companies. Since 1974, Withum has been among the nation’s top providers of audit and tax services to registered and unregistered investment companies. Our expertise spans the spectrum of asset classes and strategies. Our professionals go well beyond the commoditized accounting firm services when partnering with our alternative investment fund clients in order to deliver the best structuring, compensation and operational advice possible. With expertise in allocations, structuring, financial products, strategies, liquidity, technology, regulatory and resources, Withum will bring a world of experience to your firm. To learn more on how we can help you be in a position of strength, visit w w w.withum.com. Crowe LLP (w w w.crowe.com) is a public accounting, consulting and technology firm with of fices around the world. Crowe uses its deep industry expertise to provide audit services to public and private entities. The firm also helps clients make smart decisions that lead to lasting value with its tax, advisory, risk and performance services. Crowe is recognized by many organizations as one of the best places to work in the U.S. As an independent member of Crowe Global, one of the largest global accounting networks in the world, Crowe serves clients worldwide. The network consists of more than 200 independent accounting and advisory services firms in 130 countries around the world.

To Register: Call 800-280-8440 or visit us at www.frallc.com


Silver Sponsor GlobeTax helps clients maximize investment returns by ensuring that investors receive all income to which they are legally entitled. GlobeTax is the leading provider of withholding tax recovery services for institutional and high-net worth investors receiving cross-border investment income. Additionally, GlobeTax manages the market infrastructure for tax reclaims on American Depositary Receipts (ADRs) as the agent for the issuing depositary banks. GlobeTax has strategic alliances with all major prime brokers and services over 750 hedge funds. Founded in 1992, GlobeTax has of fices on four continents and clients in over 40 countries, filing over 6. 5 million reclaims a year. w w w. globetax.com

Bronze Sponsor

To Register: Call 800-280-8440 or visit us at www.frallc.com


THE 9TH ANNUAL PRIVATE INVESTMENT FUNDS TAX MASTER CLASS

WILMINGTON FRA 3420 TORINGDON WAY, SUITE 240 CHARLOTTE, NC 28277

Three Ways to Register

Call 800.280.8440

Web

Mail

www.frallc.com

Wilmington FRA 3420 Toringdon Way, Suite 240 Charlotte, NC 28277

ATTENTION MAILROOM: If undeliverable, please forward to the

CHIEF FINANCIAL OFFICER

Please Mention This Priority Code When Registering

Early Bird (Ends 4/27/18)

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Payment Method: Payments must be received no later than May 15, 2018

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INCORRECT MAILING INFORMATION: If you are receiving multiple mailings, have updated information or would like to be removed from our database, please fax our database team at 704.341.2641 or call 704.341.2387. Please keep in mind that amendments can take up to 8 weeks.

Conference Code: B1075

T H E 9TH A N N U A L

PRIVATE INVESTMENT FUNDS TAX MASTER CLASS The Industry’s Most Complete and Concise Tax Event for both Private Equity Funds and Hedge Funds May 22-23, 2018

|

The Princeton Club

|

New York City

How will new tax legislation affect your fund’s planning going forward?

To Register: Call 800-280-8440 or visit at www.frallc.com Earnus13.5 CPE Tax Credits

The 9th Annual Private Investment Funds Tax Master Class  

The Industry’s Most Complete and Concise Tax Event for both Private Equity Funds and Hedge Funds

The 9th Annual Private Investment Funds Tax Master Class  

The Industry’s Most Complete and Concise Tax Event for both Private Equity Funds and Hedge Funds