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Announcing the launch of our new Investment Management Tax Reporting and Withholding Conference, to be held on Wednesday, January 22, 2025, 8:30 a.m. - 4:00 p.m. at Arch Meetings & Events, 1166 Avenue of the Americas, 12th Floor, New York, NY.
Register here to hear from IRS and industry experts on need-to-know tax reporting and withholding information for asset managers and partnership funds.
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CONFERENCE PROGRAM
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Registration & Networking Breakfast
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Welcome and Opening Remarks
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Panel 1: Introduction to Partnership Taxation and Structure
Understanding the basics of partnership tax and structures is necessary to connect the key areas of information reporting and withholding for investment management. This session will cover partnership income; distributions vs. allocations; filings (Schedules K-1, K-2, and K-3); general and limited partners; and fund structures and tiered partnerships.
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Panel 2: FDAP Withholding and Reporting
Partnerships are common vehicles for foreign investors to get exposure to the U.S. market. Partnerships may be obligated to withhold on payments (or allocations) of certain US source FDAP income to foreign partners and report on Forms 1042 & 1042-S. This session will cover the basics of FDAP withholding and reporting, as well as special rules related to the application of the lag method, and those partnerships that are withholding foreign partnerships.
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Panel 3: Withholding on Effectively Connected Income
Special withholding and reporting rules apply to partnerships that earn and allocate income that is effectively connected with a U.S. trade or business (ECI) to foreign partners. This session will address the documentation requirements for foreign partners allocated ECI, and the associated withholding and reporting on Forms 8804 and 8805. Special rules applicable to sales of U.S. Real Property Interests and sales of interests in partnerships by foreign partners (section 1446(f)) will also be discussed.
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Panel 4 FATCA/CRS Reporting
Partnership funds and certain other entities within fund structures must ensure they are properly collecting documentation and reporting to multiple jurisdictions for both FATCA and CRS purposes on many of the entities’ partners/owners. This panel will discuss best practices around entity classification, data collection, data wrangling, monitoring of various jurisdictional updates and integrating those into your reporting processes. Panelists will also discuss the implementation of the amendments to the CRS.
Additionally, as jurisdictions outside the U.S. are making FATCA and CRS inquiries and, in some instances, instituting penalties, the panel will discuss best practices to address these matters.
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Panel 5 Tax Controversy
This session will focus on IRS audits and other enforcement efforts on partnerships in fund structures. The panel will provide insights on emerging compliance trends, as well as current enforcement priorities and initiatives.
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Panel 6 Investments in Digital Assets
With the growing digital asset market, more and more partnerships are investing with the potential for generating reportable income related to their digital asset activity. This session will discuss potential reporting and withholding under U.S. and international withholding and reporting regimes, such as the EU’s DAC 8, OECD’s CARF regimes and the newly released U.S. §6045 broker regulations.
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Concluding Remarks
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Thank you to our inaugural event sponsors:
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