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Real Estate Tax Forum (19th Annual)
Chair(s):
Blake D. Rubin, Leslie H. Loffman, Sanford C. Presant
Practice Area:
Corporate law,
Corporate tax,
Partnership tax,
Real estate,
Real estate taxes,
Tax
Published:
Feb 2017
i
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ISBN:
9781402428289
PLI Item #:
186465
CHB Spine #:
D476, D477, D478
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Table of Contents
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Front Matter
Faculty Bios
Table of Contents to Vol. 1
Table of Contents to Vol. 2
Table of Contents to Vol. 3
Chapter 1. Recent Developments Affecting Real Estate and Pass Through Entities (October 31, 2016)
Chapter 2. Recent Developments in Partnership and Real Estate Taxation in 2015 (September 1, 2016)
Chapter 3. Developments in Partnership and Real Estate Taxation in 2015 (October 1, 2015)
Chapter 4. Developments in Partnership and Real Estate Taxation in 2014 (September 1, 2014)
Chapter 5. Developments in Partnership and Real Estate Taxation in 2013
Chapter 6. Developments in Partnership and Real Estate Taxation in 2012
Chapter 7. Developments in Partnership and Real Estate Taxation in 2011
Chapter 8. Developments in Partnership and Real Estate Taxation in 2010
Chapter 9. Jobs Act Tightens Partnership Tax Rules
Chapter 10. Tax Planning for Partnership Options and Compensatory Equity Interests
Chapter 11. Joint Ventures with Tax-Exempt Entities and Taxable Operators (Including REITs)
Chapter 12. Choice of Entity—Business and Tax Considerations
Chapter 13. Tax Aspects of the Initial Partnership or LLC Negotiation
Chapter 14. Selected Operating Agreement Tax Allocation Provisions for Limited Liability Companies
Chapter 15. Income Recognition Checklist (Problems)
Chapter 16. A Section 754 Paradox: Basis Step-Up Triggers Gain Recognition in UPREIT and Other Partnership Contribution Transactions
Chapter 17. Proposed Regulations on Allocating Partnership Liabilities to Owners of Disregarded Entities
Chapter 18. Put a “Bottom” Deficit Restoration Obligation in Your Partnership Liability Allocation Tool Box (September 1, 2014)
Chapter 19. Final Regulations on the Treatment of Disregarded Entities for Purposes of Characterizing and Allocating Liabilities Under Code Sec. 752: Questions and Complexities Continue
Chapter 20. Rev. Rul. 99-43: When to Hold’em, When to Fold’em, and When to Book-Down
Chapter 21. Exploring the Outer Limits of Section 704(c)(1)(A)
Chapter 22. Final Partnership Liability Regulations Target “Son of Boss” Abuse But Sweep More Broadly
Chapter 23. The Impact of a Capital Account Deficit Restoration Obligation on a Partner’s At-Risk Amount and Share of Liabilities: Hubert Enterprises, Inc. v. Commissioner
Chapter 24. Sixth Circuit Vacates Controversial Hubert Case Dealing with Partner’s At-Risk Amount
Chapter 25. Tax Court Sticks to Its Guns and Sticks It to Taxpayers in Hubert Case
Chapter 26. New Regulations Regarding Assumption of Partnership Liabilities
Chapter 27. The Proposed Regulations on Partnership Allocations with Respect to Contributed Property
Chapter 28. New Ruling on Allocating Partnership Liabilities Disregards Technicalities to Absolve Taxpayer of Gain
Chapter 29. Planning for Partnership Liability Allocations, Including the New Proposed Regulations (January 2015)
Chapter 30. Final and Proposed Regulations Regarding Partnership Noncompensatory Options (January 2014)
Chapter 31. Testimony Before the Subcommittee on Select Revenue Measures (May 15, 2013)
Chapter 32. New Taxpayer Favorable PLRs Allow Gain on Sale of Partnership Assets to Be Offset by Disallowed Loss on Earlier Sale of Partnership Interest (April 2016)
Chapter 33. Partnership Disguised Sales of Property: G-I Holdings Misses the Mark
Chapter 34. Tax Court Goes Overboard in Canal
Chapter 35. Implications of Canal Corporation for Structuring Partnership Transactions
Chapter 36. Recent Developments Regarding Disguised Sales of Partnership Interests
Chapter 37. Disguised Sales of Partnership Interests: An Analysis of the Proposed Regulations
Chapter 38. Tax Court Respects Partnership’s Property Distribution: Countryside Limited Partnership v. Commissioner
Chapter 39. Proposed Regulations on Partnership Interests Issued for Services Create Problems and Opportunities
Chapter 40. Is Your Transaction a Partnership Merger or Liquidation and Why You Should Care (January 2015)
Chapter 41. New Proposed Regulations on Mergers Involving Disregarded Entities
Chapter 42. Partnership Mergers, the Anti-Mixing Bowl Rules and Rev. Rul. 2004-43: How Could the Service Be So Wrong?
Chapter 43. Proposed Regulations on Application of the Anti-Mixing Bowl Rules After a Partnership Merger to Apply Prospectively
Chapter 44. Handling Partnership Mergers and Divisions
Chapter 45. A Comprehensive Guide to Partnership Terminations, Including the Impact of the New Proposed Regulations
Chapter 46. Partnership Equity Extraction Techniques (September 1, 2015)
Chapter 47. Taxation of Real Estate Investment Trusts ("REITs")
Chapter 48. Dealer Sales Rules for Real Estate Investment Trusts
Chapter 49. Protecting OP Unitholders in REIT Going Private Transactions
Chapter 50. Negotiating Acquisitions Using OP Units
Chapter 51. Opportunities and Pitfalls for the Property Owner in Transactions with a REIT
Chapter 52. Investment in U.S. Real Estate by Sovereign Wealth Funds—Tax Issues
Chapter 53. New Ruling on Like-Kind Exchanges of Leveraged Property Solves Problems and Creates Opportunities
Chapter 54. Defeasing Conduit Loans: Tax Issues, Premiums, Like-Kind Exchanges and “New York Style” (May 2015)
Chapter 55. Capital Gains Planning
Chapter 56. Maximizing Capital Gains in Real Estate Transactions: Case Studies
Chapter 57. Disposition of Real Estate—Capital Gain vs. Ordinary Income
Chapter 58. Rev. Rul. 2016-15 Holds Real Estate Dealers Cannot Exclude Cancellation of Indebtedness Income, But Is It Correct?
Chapter 59. "Bad Boy" Nonrecourse Carve-Outs in Real Estate Loan Cause It to Be Recourse—or Do They? (May 2016)
Chapter 60. Cancellation of Indebtedness Income Deferral in Economic Stimulus Bill Raises Complex Issues for Partnerships
Chapter 61. Rev. Proc. 2009-37 Allows Flexibility for Partnerships Electing New C.O.D. Income Deferral
Chapter 62. Recourse or Nonrecourse: Liability Treatment for COD and Other Purposes
Chapter 63. Is It Cancellation of Debt (COD) Income?: New IRS Chief Counsel Advice Takes the Gas out of Great Plains Gasification (September 1, 2015)
Chapter 64. Debt Workouts: The Partnership and the Partners
Chapter 65. Tax Primer for Partnership Workouts
Chapter 66. Important Tax Developments Affecting Partnership Workouts
Chapter 67. Tax Aspects of Real Estate Workouts
Chapter 68. Creditors Beware: Proposed Partnership Debt-for-Equity Regulations Deny Your Tax Loss
Chapter 69. Tax Planning for the Sale or Other Disposition of Overencumbered Real Estate
Chapter 70. Partnership Bankruptcy Tax Issues
Chapter 71. Chapter 8: The Trouble with Troubled Partnerships
Chapter 72. Final Partnership Debt-for-Equity Regs Deny Creditors’ Losses
Chapter 73. Revenue Ruling 2012-14: The IRS Lends a Helping Hand to Insolvent Partners
Chapter 74. The Tax Treatment of Environmental Cleanup Costs
Chapter 75. Creative Planning for Partnership Liability Allocations, Including the New Proposed Regulations (PowerPoint slides)
Chapter 76. Selected Tax Allocation Problems for Partnerships and LLCs (PowerPoint slides)
Chapter 77. Allocation Examples (PowerPoint slides)
Chapter 78. Tax Provision Issues Checklist for LLC and Partnership Agreements (PowerPoint slides)
Chapter 79. Handling UPREIT and DownREIT Transactions: Latest Techniques and Issues (PowerPoint slides)
Chapter 80. Making Section 704(c) Work for You (PowerPoint slides)
Chapter 81. Investments in United States Real Property by Non-U.S. Investors—U.S. Tax Considerations (PowerPoint slides)
Chapter 82. Non-U.S. Investors Participating in Your U.S. Real Estate Deal (PowerPoint slides)
Chapter 83. Current Issues in Like-Kind Exchanges (PowerPoint slides)
Chapter 84. Partnerships and Disregarded Entities in Like-Kind Exchanges (PowerPoint slides)
Chapter 85. Maximizing Capital Gains in Real Estate Transactions (PowerPoint slides)
Chapter 86. Hot Like-Kind Exchange Issues (PowerPoint slides)
Chapter 87. Leasing Issues (PowerPoint slides)
Chapter 88. Capital Gains Planning (PowerPoint slides)
Chapter 89. Disposing of Overleveraged Real Estate: Thinking Outside the Box (PowerPoint slides)
Chapter 90. Debt Workouts and Restructurings (PowerPoint slides)
Index
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