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  • ON-DEMAND

Partnership and LLC Equity Strategies: Profits, Capital, and Option Planning (On-Demand)

General Credits:
Original Date Of Course:

$179.00

Course Description

Attorneys will learn how pass-through equity compensation differs from corporate structures, including the core equity toolbox, tax mechanics, Section 83 and 409A considerations.

Attorneys will gain practical knowledge for drafting and implementing profits interests, capital interests, options, and phantom equity in partnerships and LLCs.

Syllabus

  1. Profits Interests
    • Non-taxable grants requiring hurdles at fair market value under Revenue Procedures 93-27 and 2001-43
  2. Capital Interests
    • Ownership in current and future value that may trigger Section 83 inclusion events
  3. Section 83(b)
    • Elections must be filed within 30 days of grant with no late relief available
  4. Section 409A
    • No post-vesting discretion permitted; payment must occur upon specific permitted events only
  5. Partner Status
    • Recipients of partnership interests cannot be employees and shift from W-2 to K-1 reporting
  6. Allocation Mechanics
    • Capital account driven allocations follow ownership percentages; targeted allocations define liquidation waterfalls first

Credit Details

Course Type

Course Instructor

Angela M. Stockbridge, Esq., Matthew E. Foreman, Esq.
Original Date Of Course

General Credits

1.5
Angela M. Stockbridge, Esq.
Angela M. Stockbridge, Esq.
Angela M. Stockbridge, Esq. is an employee benefits and executive compensation attorney with experience across law firms, in-house legal departments, and HR consulting roles. She holds a Juris Doctor from Cornell Law School and a Bachelor of Arts in Psychology from the University of Texas, and is admitted to practice in Texas.
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Matthew E. Foreman, Esq.
Matthew E. Foreman, Esq.
Matthew E. Foreman, Esq. co-chairs the Taxation Practice Group at FRB and advises clients on transactional tax matters spanning acquisitions, mergers, reorganizations, and cross-border transactions, with particular expertise in tax-free restructurings across regulated industries. He holds a Master of Laws in Taxation from New York University School of Law and a J.D. from Penn State Dickinson School of Law, and is admitted to practice before the U.S. Tax Court and in New York and New Jersey.
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