Alston & Bird presented a first-ever seminar titled "Tax Conference on Hedge Fund Structuring & Compensation". Topics of discussion included:
Hedge Fund Structuring Issues
• Corporation v. Partnership
• US v. Foreign Fund
• Parallel Fund Structures
• Master Feeder Structures
• Relationship to Compensation Issues
• Securities Law Issues
• Derivative Investments in Hedge Funds
Deferred Compensation Issues
• Taxation of Carried Interests
• Application of Section 409A to Deferred Management Fees
Legislative Outlook
• Taxation of Offshore Deferred Compensation
• Ordinary Income Taxation of Carried Interests
• Cap on Deferred Compensation
• Changes to UBTI Rules for Debt Financed Property
May 28, 2008
4:00pm - 6:00pm
Alston & Bird LLP / 90 Park Avenue / New York, NY