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Real Estate Tax Forum (Sixth Annual)
Chair(s):
Leslie H. Loffman, Sanford C. Presant
Practice Area:
Real estate,
Tax
Published:
Feb 2004
i
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ISBN:
1402404018
PLI Item #:
2854
CHB Spine #:
J601, J602, J603
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Table of Contents
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Front Matter
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
Chapter 2. New Disclosure and Listing Regulations Promise Headaches for Everyone
Chapter 3. Final Corporate Tax Shelter Disclosure and List Maintenance Regulations Impose Burdens on Everyone
Chapter 4. Here Comes the Kitchen Sink: IRS Throws “Everything but” at Two Partnership Tax Deferral Structures
Chapter 5. IRS Bars Acquisition of Replacement Property from Related Parties—Or Does it?
Chapter 6. Long-Awaited 469 Final Regs. On Self-Charged Items—IRS Holds the Line on Interest Only
Chapter 7. Joint Ventures with REITs and Tax-Exempt Entities
Chapter 8. Tax Planning for the Property Owner in REIT Acquisitions
Chapter 9. Doing a Deal With a REIT: UPREITS, Down REITS and Other Structures (Slides)
Chapter 10. The Ups and Downs of Down REITs
Chapter 11. Tax Treatment of REITs and REIT Shareholders
Chapter 12. REIT Mergers & Acquisitions: Tax Consequences
Chapter 13. New Ruling Permits REITS to Make Subordinated Loans…….
Chapter 14. Income Recognition Checklist for Property Contributions to UPREITS and Other Partnerships
Chapter 15. Income Recognition Checklist (Problems)
Chapter 16. Effecting Tax-Free Property Contributions to UPREITs and Other Partnerships
Chapter 17. Avoid Taxes for Property Contributions: Transferring to UPREITs and Other Partnerships
Chapter 18. Avoiding Phantom Income Traps in Real Estate LLCs and Partnerships
Chapter 19. A Section 754 Paradox: Basic Step-Up Triggers Gain Recognition in UPREIT and Other Partnership Contribution Transactions
Chapter 20. Creative Transactional Planning Using the Partnership Merger and Division Regulations
Chapter 21. The History of Section 704(b)
Chapter 22. Rev. Rul. 99-43: When to Hold’em, When to Fold’em, and When to Book-Down
Chapter 23. Exploring the Outer Limits of Section 704(c)(1)(A)
Chapter 24. Take the Money and Run: Extracting Equity on a Tax-Free Basis
Chapter 25. Extracting Equity on a Tax-Free Basis
Chapter 26. Allocation of Nonrecourse Liabilities: IRS Takes Two Steps Forward, One Back
Chapter 27. Allocating Partnership Liabilities Under Section 752 of the Internal Revenue Code
Chapter 28. New Ruling on Allocating Partnership Liabilities Disregards Technicalities to Absolve Taxpayer of Gain
Chapter 29. Supreme Court Hands Taxpayers a Victory in Gitlitz, But Will Congress Take it Away?
Chapter 30. New Decision Casts a Shadow on the Contested Liability Exception to COD Income
Chapter 31. Briarpark and the Unexpected Limits to Careful Tax Planning
Chapter 32. Unsecured Borrowing Treated as Qualified Nonrecourse Financing Under Code Secs. 752 and 465
Chapter 33. IRS Issues Taxpayer-Friendly Qualified Nonrecourse Financing Regs
Chapter 34. Taxation of Real Estate Investment Trusts (“REITS”)
Chapter 35. Recent Developments Regarding Disguised Sales of Partnership Interests
Chapter 36. Real Estate Investment Trusts: A Guide to Their History, Formation and Taxation
Chapter 37. Dealer Sales Rules for Real Estate Investment Trusts
Chapter 38. Real Estate Workouts – A Step By Step Analysis
Chapter 39. Tax Aspects of Real Estate Workouts
Chapter 40. Peracchi and Making Something out of Nothing, or Does Debt Have a Zero Basis to its Maker and Further Ruminations on the Substance and Form of Transactions
Chapter 41. Creative Strategies for the Disposition of Overleveraged Real Estate
Chapter 42. Creative Strategies for the Disposition of Overleveraged Real Estate(Slides)
Chapter 43. Final Section 467 Regulations Present Problems and Opportunities
Chapter 44. Tax Treatment of Environmental Remediation Costs
Chapter 45. The Tax Treatment of Environmental Cleanup Costs
Chapter 46. Maximizing Capital Gains in Real Estate Transactions
Chapter 47. Maximizing Capital Gains in Real Estate Transactions (Slides)
Chapter 48. Capital Gains: Some Hidden Traps (Slides)
Chapter 49. New Proposed Regulations on Mergers Involving Disregarded Entities
Chapter 50. Investment in Real Estate by Tax-Exempt Investors
Chapter 51. Maximizing Capital Gains in Real Estate Transactions: Case Studies
Chapter 52. Disposition of Real Estate – Capital Gain vs. Ordinary Income
Chapter 53. Preserving Capital Gains in Real Estate Transactions
Chapter 54. Critical Partnership Tax Issues – An Overview
Chapter 55. Choice of Entity—Business and Tax Considerations…
Chapter 56. Final PTP Regs. Abandon Restrictive Conditions and Adopt Workable New Exemptions
Chapter 57. Tax Aspects of the Initial Partnership or LLC Negotiation
Chapter 58. Negotiating Acquisitions Using OP Units
Chapter 59. Final Allocation Regulations Add Simplicity but Retain Planning Opportunities
Chapter 60. Creative Planning To Control Partnership Liability Allocations
Chapter 61. Creative Planning To Control PartnershipLiability Allocations (Slides)
Chapter 62. New Regulations Regarding Assumption of Partnership Liabilities
Chapter 63. The Proposed Regulations on Partnership Allocations with Respect to Contributed Property
Chapter 64. Selected Tax Allocation Problems for Partnerships and LLCs
Chapter 65. Selected Operating Agreement Tax Allocation Provisions for Limited Liability Companies
Chapter 66. Tax Issue Raised by Partnership Options
Chapter 67. Tax Primer for Partnership Workouts
Chapter 68. Important Tax Developments Affecting Partnership Workouts
Chapter 69. Planning for the Termination of an Interest in a Partnership –Withdrawals, Distributions and Other Exit Strategies
Chapter 70. Tax Accounting for Real Estate Leases:The Final Section 467 Regulations
Chapter 71. Leasing Dot.Coms (and Other High-Tech Start-Ups):What the Parties to the Lease Should Know
Chapter 72. Estate Planning with Real Estate Assets
Chapter 73. Fundamentals of Taxation of Foreign Investors
Chapter 74. The ‘State of the Art’ in Like-Kind Exchanges – Revisited
Chapter 75. Current Issues in Like-Kind Exchanges (Slides)
Chapter 76. New Revenue Procedure on Reverse Like-Kind Exchanges Replaces Tax Risk with Tax Certainty
Chapter 77. New Rules Likely to Increase Use of Tenancy-in-Common Ownership in Like-Kind Exchanges
Chapter 78. Multi-Year Deferred Like-Kind Exchanges By Partnerships—Is the New Rev. Rul. a Trojan Horse?
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