videocam Live Webinar with Live Q&A
calendar_month July 7, 2026 @ 1:00 PM ET/10:00 AM PT
signal_cellular_alt Intermediate
card_travel Tax Law
schedule 90 minutes

Hedge Fund Tax Planning and Compliance: Fund Structures, Section 704, Tax Strategies for Managers and Investors

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About the Course

Introduction

This CLE/CPE course will provide tax counsel guidance on tax compliance, reporting, and planning strategies for fund managers and investors of hedge funds under current tax law. The panel will discuss structuring considerations for new funds, navigating carried interest rules under Sec. 1061, management fees, receipt of profits interests and Rev. Proc. 93-27, the impact of the One Big Beautiful Bill Act (OBBBA), and other critical tax considerations for fund managers and investors.

Description

In structuring hedge funds, the competing tax preferences of different types of fund investors are critical. The different types include U.S. taxable, U.S. tax-exempt, U.S. government, non-U.S. taxable, non-U.S. pension funds, and non-U.S. sovereign investors. Fund structures can use "blockers" and feeder funds to address these various interests and minimize U.S. taxes.

Tax counsel must understand current issues, such as FATCA for non-U.S. investment entities and investors, the impact of OBBBA for both fund managers and fund investors, and carried interest rules.

The program will conclude with an overview of typical investment fund documents and tax provisions, such as those addressing effectively-connected income and unrelated business taxable income.

Listen as our panel provides an analysis of the different and competing tax preferences of fund investors and outlines sophisticated best practices for structuring hedge funds to accommodate the myriad interests of these investors.

Credit Information

This 90-minute webinar is eligible in most states for 1.5 CLE credits.
CPE credit is not available on recordings.
BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.
BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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Date + Time

event
Tuesday, July 7, 2026
schedule
1:00 PM ET/10:00 AM PT

I. The impact of OBBBA

II. Tax objectives of taxable U.S. investors

III. Tax objectives of non-taxable U.S. investors (pension plans, endowments, other tax-exempt investors and governmental entities)

IV. Tax objectives on non-U.S. investors

V. Tax objectives of sovereign investors

VI. Tax objectives of fund managers

VII. Fund structuring issues and options

The panel will review these and other vital questions:

What are the competing tax preferences of fund investors that practitioners must juggle when structuring hedge funds?
How can the use of blockers and feeder funds accommodate the needs of particular investors?
What challenges face sovereign investors in retaining their status as Section 892 investors in light of recent regulations?
How do the OBBBA tax rules impact tax planning when structuring hedge funds?

Learning Objectives

After completing this seminar, you will be able to:

Determine the structure of hedge and other types of funds
Recognize various factors in tax planning when structuring investment funds
Identify key tax provisions under new tax law impacting hedge funds
Ascertain tax planning methods to avoid tax pitfalls in structuring investment funds

Field of Study: Taxes
Level of Knowledge: Intermediate
Advance Preparation: None
Teaching Method: Seminar/Lecture
Delivery Method: Group-Internet (via computer)
Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
Prerequisite:
Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of pass-through taxation, including taxation of partnerships, S corporations and sole proprietorships, qualified business income, net operating losses and loss limitations; familiarity with net operating loss carry-backs, carry-forwards and carried interests.

BARBRI, Inc. 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 Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .