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Tax Readiness: Unlocking value and mitigating risks in an Up-C structure

November 4, 2025 @ 2:00 pm – 3:00 pm EST
As companies prepare for IPOs, SPAC transactions or private equity exits, many are turning to an “Up-C” structure — a deal and holding structure where pre-IPO owners retain their operating business in a tax partnership while public investors hold stock in a newly formed C corporation that sits “above” the partnership. Up-C structures can provide significant tax advantages, but they also add unique complexity. This session will explore how tax leaders may prepare and strengthen financial, tax and Tax Receivable Agreement (TRA) reporting processes within an Up-C structure. From pre-IPO readiness to post-IPO operations, we will outline practical actions to mitigate risk, streamline processes, enhance coordination with finance teams and create long-term value across the Up-C lifecycle. This webcast is CPE-eligible for 1 Tax credit.





