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Getting Vertical

Private equity, venture capital and hedge fund estate-planning pitfalls.

Trusts and estates attorneys who work with clients who run private equity (PE), venture capital (VC) and hedge funds regularly rely on the “vertical slice” exception to Internal Revenue Code Section 2701 to transfer interests in those funds to their descendants. It’s widely accepted by practitioners in this space that if a general partner (GP) transfers an equal proportion of each class of his equity in a fund, the draconian valuation methodology of IRC Section 2701 won

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