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Nov 1, 2010 12:00 PM
Going Non-Vertical With Fund Interests
Creative carried interest transfer planning: When the “vertical slice” won't cut it
The vagaries and draconian nature of Internal Revenue Code Section 2701 have understandably led to widespread deference to the “vertical slice rule.” However, it is essential to bear in mind that the “vertical slice” isn't actually a rule, but rather one of a number of exceptions to the application of Section 2701. When adherence to the vertical slice exception isn't feasible or would produce an undesirable result for your client, you should consider alternative approaches.
Over the past 24 months, despite the obvious transfer tax advantages, inherent wealth transfer planning opportunities that existed due to the economic downturn were simply not as much of a priority for many fund principals as they had been previously.
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| Estate Tax | Donor Advised Funds |
| GSTs | Family Offices |
| Private Foundations | Life Insurance |
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Topics of Interest
| Estate Tax | Donor Advised Funds |
| GSTs | Family Offices |
| Private Foundations | Life Insurance |
| 2010 Tax Act News | Industry Trends Surveys |
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