This program will contain a discussion of the technical provisions of Section 2701 including historical context and various planning pitfalls. It will also include a discussion of planning applications with Section 2701 including various Preferred Partnership applications, Carried Interest Transfer Planning including a discussion of Vertical Slice and Non-Vertical approaches and Profits Interests.
1. Gain an appreciation of Section 2701 technical provisions and policy rationale behind the statute.
2. Gain an awareness for the various different scenarios in which Section 2701 can trigger an unintentional deemed gift
3. Gain an understanding of different pro-active planning opportunities with Preferred Partnerships and other Section 2701 compliant vehicles