The 9th Annual Private Investment Funds Tax Master Class

Page 7

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


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