
Estate Planning for Principals of Private Equity and Hedge Funds
ACTEC Trust & Estate Talk
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What's the Impact of 27 O One?
The impact of 27 o one is that those applicable retained interests are that distribution right to be valued at zero in the fund taxt. If you rin t make a gift and hold on to a portion of your carrir or capital interest to make a gift of it, if your interest that you retain is goig to bevalued at zero, that could be a substantially larger gift than you'd intended on making in the first instance. So you really do have to pay attention to 27 o one when you're doing fun planning. There are certain exceptions. Way is to plan that we know, or knock on a trigger, 27 o one.
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