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Real Estate Tax Forum (Fourth Annual)
Chair(s):
Leslie H. Loffman, Sanford C. Presant
Practice Area:
Real estate,
Tax
Published:
Feb 2002
i
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ISBN:
1402400993
PLI Item #:
406
CHB Spine #:
J522, J523, J524, J525
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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. Joint Ventures with REITs and Tax-Exempt Entities
Chapter 3. Tax Planning for the Property Owner in REIT Acquisitions
Chapter 4. Doing a Deal With a REIT: UPREITs, DownREITs and Other Structures (Slides)
Chapter 5. The Ups and Downs of DownREITs
Chapter 6. Tax Treatment of REITs and REIT Shareholders
Chapter 7. REIT Mergers & Acquisitions: Tax Consequences
Chapter 8. Income Recognition Checklist for Property Contributions to UPREITs and Other Partnerships
Chapter 9. Income Recognition Checklist (Problems)
Chapter 10. Effecting Tax-Free Property Contributions to UPREITs and Other Partnerships
Chapter 11. Avoid Taxes for Property Contributions: Transferring to UPREITs and Other Partnerships
Chapter 12. Avoiding Phantom Income Traps in Real Estate LLCs and Partnerships
Chapter 13. A Section 754 Paradox: Basic Step-Up Triggers Gain Recognition in UPREIT and Other Partnership Contribution Transactions
Chapter 14. Creative Transactional Planning Using the Partnership Merger and Division Regulations
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. Take the Money and Run: Extracting Equity on a Tax-Free Basis
Chapter 22. Extracting Equity on a Tax-Free Basis
Chapter 23. The Section 737 Regulations
Chapter 24. Allocation of Nonrecourse Liabilities: IRS Takes Two Steps Forward, One Back
Chapter 25. Issues in Partnership Liabilities
Chapter 26. Allocating Partnership Liabilities Under Section 752 of the Internal Revenue Code
Chapter 27. Supreme Court Hands Taxpayers a Victory in Gitlitz, but Will Congress Take it Away?
Chapter 28. New Decision Casts a Shadow on the Contested Liability Exception to COD Income
Chapter 29. Briarpark and the Unexpected Limits to Careful Tax Planning
Chapter 30. Unsecured Borrowing Treated as Qualified Nonrecourse Financing Under Code Secs. 752 and 465
Chapter 31. IRS Issues Taxpayer-Friendly Qualified Nonrecourse Financing Regs
Chapter 32. Taxation of Real Estate Investment Trusts ("REITs")
Chapter 33. An Inquiry into Certain Income Tax Aspects of Investment Partnerships
Chapter 34. Tax Aspects of Partnership Dilution Provisions
Chapter 35. Dissecting the Regulations on Partnership Disguised Sales Under Section 707(a)(2)(B)
Chapter 36. Liabilities Under the Disguised Sale Rules of Section 707
Chapter 37. Sales of Partnership Interests
Chapter 38. Recent Developments Regarding Disguised Sales of Partnership Interests
Chapter 39. IRS Attempts to "Demonize" the Partnership: The Final Section 701 Regulations – Antiabuse Regulations or Simply Abusive Regulations?
Chapter 40. Tax Aspects of Real Estate Investment Trusts
Chapter 41. Real Estate Investment Trusts: A Guide to Their History, Formation and Taxation
Chapter 42. Planning for Taxable Acquisitions Involving Real Estate Investment Trusts
Chapter 43. Dealer Sales Rules for Real Estate Investment Trusts
Chapter 44. Real Estate Workouts – A Step by Step Analysis
Chapter 45. Tax Aspects of Real Estate Workouts
Chapter 46. Nonrecourse Debt and Securitized Financing
Chapter 47. 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 48. Creative Strategies for the Disposition of Overleveraged Real Estate
Chapter 49. Creative Strategies for the Disposition of Overleveraged Real Estate (Slides)
Chapter 50. Final Section 467 Regulations Present Problems and Opportunities
Chapter 51. The Tax Treatment of Environmental Cleanup Costs
Chapter 52. Tax Treatment of Environmental Remediation Costs
Chapter 53. Maximizing Capital Gains in Real Estate Transactions
Chapter 54. Maximizing Capital Gains in Real Estate Transactions (Slides)
Chapter 55. Maximizing Capital Gains in Real Estate Transactions: Case Studies
Chapter 56. Disposition of Real Estate – Capital Gain vs. Ordinary Income
Chapter 57. Preserving Capital Gains in Real Estate Transactions
Chapter 58. Closing Agents in Section 1031 Exchanges
Chapter 59. Liabilities in Section 1031 Exchanges
Chapter 60. Tax Ghosts Under Section 1031
Chapter 61. Taxing Ghosts Under Section 1031 - Part II
Chapter 62. Critical Partnership Tax Issues – An Overview
Chapter 63. Choice of Entity–Business and Tax Considerations
Chapter 64. The "Check the Box Regulations" and Partnership Tax Status
Chapter 65. Comings and Goings: New Rulings Address Entity Conversions Resulting from Changes in Ownership
Chapter 66. Final PTP Regs. Abandon Restrictive Conditions and Adopt Workable New Exemptions
Chapter 67. Series LLC's and the Abolition of the Tax System
Chapter 68. Tax Aspects of the Initial Partnership or LLC Negotiation
Chapter 69. Tax-Efficient Strategies for Selling Real Estate Partnership Interests
Chapter 70. Negotiating Acquisitions Using OP Units
Chapter 71. Final Allocation Regulations Add Simplicity but Retain Planning Opportunities
Chapter 72. The Proposed Regulations on Partnership Allocations with Respect to Contributed Property
Chapter 73. Selected Tax Allocation Problems for Partnerships and LLCs
Chapter 74. Selected Operating Agreement Tax Allocation Provisions for Limited Liability Companies
Chapter 75. A Personal Perspective on Drafting Partnership and LLC Agreements
Chapter 76. Tax Primer for Partnership Workouts
Chapter 77. Important Tax Developments Affecting Partnership Workouts
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. Tax Accounting for Leases: The Final Section 467 Regulations
Chapter 82. Leasing Dot.Coms (and Other High-Tech Start-Ups): What the Parties to the Lease Should Know
Chapter 83. Estate Planning for Real Estate
Chapter 84. Fundamentals of Taxation of Foreign Investors
Chapter 85. Foreign Investments in U.S. Real Property Structuring Alternatives
Chapter 86. Cross Border Real Estate Transactions – Structuring Alternatives (Slides)
Chapter 87. Deferred Exchanges and How to Become a Millionaire
Chapter 88. Selected Issues in Exchanges: Intermediary Agreements, Parking Arrangements, and Built-to-Suit Exchanges
Chapter 89. Issues in Cashing Out of an Exchange
Chapter 90. Real Estate and the Deferred Exchange Regulations
Chapter 91. Section 1031 Exchanges and Death
Chapter 92. Related Party Exchanges – An Examination of Technical Advice Memorandum 9748006
Chapter 93. Identification of Multiple Replacement Properties in a Deferred Exchange
Chapter 94. How Do You Do an Exchange with a Special Purpose Entity?
Chapter 95. The 'State of the Art' in Like-Kind Exchanges
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
Chapter 99. Everything You Wanted to Know About Like-Kind Exchanges – Year 2001 Developments
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