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Real Estate Tax Forum (Third Annual)
Chair(s):
Leslie H. Loffman, Sanford C. Presant
Practice Area:
Real estate,
Tax
Published:
Feb 2001
i
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ISBN:
0872249131
PLI Item #:
3940
CHB Spine #:
J488, J489, J490
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Table of Contents
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Front Matter
Table of Contents
Chapter 1. Recent Developments Affecting Real Estate and Pass-Through Entities
Chapter 2. Real Estate Tax Planning - An Overview
Chapter 3. REITs Modernized
Chapter 4. Tax Planning for the Property Owner in REIT Acquisitions
Chapter 5. Doing a Deal With a REIT: UPREITs, DOWNREITs and Other Structures (Slides)
Chapter 6. The Ups and Downs of DownREITs
Chapter 7. Tax Treatment of REITs and REIT Shareholders
Chapter 8. REIT Mergers & Acquisitions: Tax Consequences
Chapter 9. Income Recognition Checklist for Property Contributions to UPREITs and Other Partnerships
Chapter 10. Income Recognition Checklist (Problems)
Chapter 11. Effecting Tax-Free Property Contributions to UPREITs and Other Partnerships
Chapter 12. Avoid Taxes for Property Contributions: Transferring to UPREITs and Other Partnerships
Chapter 13. Avoiding Phantom Income Traps in Real Estate LLCs and Partnerships
Chapter 14. A Section 754 Paradox: Basic Step-Up Triggers Gain Recognition in UPREIT and Other Partnership Contribution Transactions
Chapter 15. Tax Accounting Issues in Mergers and Acquisitions
Chapter 16. The History of Section 704(b)
Chapter 17. Rev. Rul. 99-43: When to Hold'em, When to Fold'em, and When to Book-Down
Chapter 18. Exploring the Outer Limits of Section 704(c)(1)(A)
Chapter 19. The Section 704(c)(1)(A) Regulations
Chapter 20. The Section 704(C)(1)(B) Final Regulations
Chapter 21. The Section 737 Regulations
Chapter 22. Allocation of Nonrecourse Liabilities: IRS Takes Two Steps Forward, One Back
Chapter 23. Allocating Partnership Liabilities
Chapter 24. Allocating Partnership Liabilities Under Section 752 of the Internal Revenue Code
Chapter 25. The Impact of Excluded COD Income on S Shareholders - The Tenth Circuit Gets Lost in Gitlitz
Chapter 26. New Decision Casts a Shadow on the Contested Liability Exception to COD Income
Chapter 27. Briarpark and the Unexpected Limits to Careful Tax Planning
Chapter 28. Unsecured Borrowing Treated as Qualified Nonrecourse Financing Under Code Secs. 752 and 465
Chapter 29. IRS Issues Taxpayer-Friendly Qualified Nonrecourse Financing Regs
Chapter 30. Taxation of Real Estate Investment Trusts ("REITs")
Chapter 31. An Inquiry into Certain Income Tax Aspects of Investment Partnerships
Chapter 32. Tax Aspects of Partnership Dilution Provisions
Chapter 33. Dissecting The Section 707(a)(2)(B) Regulations on Partnership Disguised Sales
Chapter 34. Liabilities Under the Disguised Sale Rules of Section 707
Chapter 35. Sales of Partnership Interests
Chapter 36. Recent Developments Regarding Disguised Sales of Partnership Interests
Chapter 37. IRS Attempts to "Demonize" the Partnership: The Final Section 701 Regulations or Simply Abusive Regulations?
Chapter 38. Tax Aspects of Real Estate Investment Trusts
Chapter 39. Real Estate Investment Trusts: A Guide to Their History, Formation and Taxation
Chapter 40. Planning for Taxable Acquisitions Involving Real Estate Investment Trusts
Chapter 41. Dealer Sales Rules for Real Estate Investment Trusts
Chapter 42. Real Estate Workouts - A Step by Step Analysis
Chapter 43. Tax Consequences of Real Estate Workouts and Bankruptcies
Chapter 44. Tax Aspects of Real Estate Workouts
Chapter 45. Nonrecourse Debt and Securitized Financing
Chapter 46. 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 47. Creative Strategies for the Disposition of Overleveraged Real Estate
Chapter 48. Creative Strategies for the Disposition of Overleveraged Real Estate (Slides)
Chapter 49. Final Section 467 Regulations Present Problems and Opportunities
Chapter 50. Tax Treatment of Environmental Remediation Costs
Chapter 51. The Tax Treatment of Environmental Cleanup Costs
Chapter 52. Maximizing Capital Gains in Real Estate Transactions
Chapter 53. Maximizing Capital Gains in Real Estate Transactions (Slides)
Chapter 54. Maximizing Capital Gains in Real Estate Transactions: Case Studies
Chapter 55. Disposition of Real Estate - Capital Gain vs. Ordinary Income
Chapter 56. Preserving Capital Gains in Real Estate Transactions
Chapter 57. Closing Agents in Secton 1031 Exchanges
Chapter 58. Liabilities in Section 1031 Exchanges
Chapter 59. Tax Ghosts Under Section 1031
Chapter 60. Choice of Entity - Business and Tax Considerations
Chapter 61. Choice of Entity and Equity Compensation
Chapter 62. The "Check the Box Regulatons" and Partnership Tax Status
Chapter 63. Comings and Goings: New Rulings Address Entity Conversions Resulting from Changes in Ownership
Chapter 64. Final PTP Regs.: Abandon Restrictive Conditions and Adopt Workable New Exemptions
Chapter 65. Series LLC's and the Abolition of the Tax System
Chapter 66. Tax Aspects of the Initial Partnership or LLC Negotiation
Chapter 67. Tax-Efficient Strategies for Selling Real Estate Partnership Interests
Chapter 68. Negotiating Acquisitions Using OP Units
Chapter 69. Final Allocation Regulations Add Simplicity but Retain Planning Opportunities
Chapter 70. Selected Tax Allocation Problems for Partnerships and LLCs
Chapter 71. Selected Operating Agreement Tax Allocation Provisions for Limited Liability Companies
Chapter 72. Tax Primer for Partnership Workouts
Chapter 73. Important Tax Developments Affecting Partnership Workouts
Chapter 74. Restructuring a Partnership: Admissions, Redemptions and Book-Ups
Chapter 75. Creative Partnership Exit Strategies
Chapter 76. Getting Out of the Deal: Creative Exit Strategies
Chapter 77. Getting Out of the Deal: Creative Exit Strategies (slides)
Chapter 78. Planning for the Termination of an Interest in a Partnership – Withdrawals, Distributions and Other Exit Strategies
Chapter 79. Bipolar Disorder and the Section 743/755 Regulations
Chapter 80. Bipolar Disorder and the Section 734/755 Regulations
Chapter 81. Estate Planning for Real Estate
Chapter 82. Estate Planning for Real Estate Owners (slides)
Chapter 83. Foreign Investor Issues
Chapter 84. Foreign Investments in U.S. Real Property Structuring Alternatives
Chapter 85. Cross Border Real Estate Transactions – Structuring Alternatives (Slides)
Chapter 86. Deferred Exchanges and How to Become a Millionaire
Chapter 87. Selected Issues in Exchanges
Chapter 88. Issues in Cashing Out of an Exchange
Chapter 89. Real Estate and the Deferred Exchange Regulations
Chapter 90. Section 1031 Exchanges and Death
Chapter 91. Related Party Exchanges – An Examination of Technical Advice Memorandum 9748006
Chapter 92. Identification of Multiple Replacement Properties in a Deferred Exchange
Chapter 93. How Do You Do an Exchange with a Special Purpose Entity?
Chapter 94. The 'State of the Art' in Like-Kind Exchanges
Chapter 95. Reverse Like-Kind Exchanges and Other Hot Exchange Issues
Chapter 96. Current Issues in Like-Kind Exchanges (Slides)
Chapter 97. Like-Kind Exchanges and Limited Liability Companies
Chapter 98. Planning Deferred Like-Kind Exchanges
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