Estate Tax Reduction Strategies Honigman（减少遗产税Honigman策略）.pdfVIP

{Estate Tax Reduction Strategies } for Private Equity Owners m o c . n a r o m e t n a l p TAblE Of cOnTEnTs PART OnE p. 2 The Carried inTeresT PART TwO p. 5 esTaTe Tax reduCTion PART ThREE p. 8 ValuaTion ConsideraTions PART fOuR p. 12 irs sPeCial ValuaTion rules Private Equity Owners one of the basic aspects of the structure of almost every private equity or venture capital fund is the “carried interest” provided to the fund sponsors. The carried interest is a share in the profits of the fund granted to the fund sponsors once the fund’s investors have achieved a certain base level of return on their cumulative investment in the fund. By tying the bulk of the fund sponsor’s compensation to the carried interest, the incentives of the fund management are directly linked to the goals of the fund investors: higher returns to the investors generate higher returns to the fund sponsor. under current income tax laws, the return on a carried interest will be taxed at in addition to the capital gains rates. in addition to the existing income tax advantages, a carried existing income interest also presents interesting opportunities for wealth transfer, including asset protection. tax advantages, a carried interest also Because of its speculative nature, a carried interest will