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Real Estate Tax Forum (16th Annual)
Chair(s):
Leslie H. Loffman, Sanford C. Presant, Blake D. Rubin
Practice Area:
Real Estate, Tax
Published:
Feb 2014
ISBN:
9781402421433
PLI Item #:
51185
CHB Spine #:
D397, D398, D399
This version is not current.
Click here for the most recent version.
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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
Chapter 2. Developments in Partnership and Real Estate Taxation in 2013
Chapter 3. Developments in Partnership and Real Estate Taxation in 2012
Chapter 4. Developments in Partnership and Real Estate Taxation in 2011
Chapter 5. Developments in Partnership and Real Estate Taxation in 2010
Chapter 6. Jobs Act Tightens Partnership Tax Rules
Chapter 7. Working with the Partnership Liability Allocation Rules: Guarantees, DROs and More
Chapter 8. Tax Planning for Partnership Options and Compensatory Equity Interests
Chapter 9. Joint Ventures with Tax-Exempt Entities And Taxable Operators (Including REITs)
Chapter 10. Choice of Entity—Business and Tax Considerations
Chapter 11. Tax Aspects of the Initial Partnership or LLC Negotiation
Chapter 12. Selected Operating Agreement Tax Allocation Provisions for Limited Liability Companies
Chapter 13. Income Recognition Checklist (Problems)
Chapter 14. Avoid Taxes for Property Contributions: Transferring to UPREITs and Other Partnerships
Chapter 15. A Section 754 Paradox: Basis Step-Up Triggers Gain Recognition in UPREIT and Other Partnership Contribution Transactions
Chapter 16. Proposed Regulations on Allocating Partnership Liabilities to Owners of Disregarded Entities
Chapter 17. Final Regulations on the Treatment of Disregarded Entities for Purposes of Characterizing and Allocating Liabilities Under Code Sec. 752: Questions and Complexities Continue
Chapter 18. Rev. Rul. 99-43: When to Hold’em, When to Fold’em, and When to Book-Down
Chapter 19. Exploring the Outer Limits of Section 704(c)(1)(A)
Chapter 20. Take the Money and Run: Extracting Equity on a Tax-Free Basis
Chapter 21. Final Partnership Liability Regulations Target “Son of Boss” Abuse But Sweep More Broadly
Chapter 22. 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 23. Sixth Circuit Vacates Controversial Hubert Case Dealing with Partner’s At-Risk Amount
Chapter 24. Tax Court Sticks to its Guns and Sticks it to Taxpayers in Hubert Case
Chapter 25. New Regulations Regarding Assumption of Partnership Liabilities
Chapter 26. The Proposed Regulations on Partnership Allocations with Respect to Contributed Property
Chapter 27. New Ruling on Allocating Partnership Liabilities Disregards Technicalities to Absolve Taxpayer of Gain
Chapter 28. IRS Stretches to Help a Taxpayer in New Disguised Sale Private Letter Ruling
Chapter 29. Partnership Disguised Sales of Property: G-I Holdings Misses the Mark
Chapter 30. Tax Court Goes Overboard in Canal
Chapter 31. Implications of Canal Corporation for Structuring Partnership Transactions
Chapter 32. Recent Developments Regarding Disguised Sales of Partnership Interests
Chapter 33. Disguised Sales of Partnership Interests: An Analysis of the Proposed Regulations
Chapter 34. Tax Court Respects Partnership’s Property Distribution: Countryside Limited Partnership v. Commissioner
Chapter 35. Proposed Regulations on Partnership Interests Issued For Services Create Problems and Opportunities
Chapter 36. New Proposed Regulations on Mergers Involving Disregarded Entities
Chapter 37. Partnership Mergers, The Anti-Mixing Bowl Rules and Rev. Rul. 2004-43: How Could the Service be So Wrong?
Chapter 38. Proposed Regulations on Application of the Anti-Mixing Bowl Rules After a Partnership Merger to Apply Prospectively
Chapter 39. Handling Partnership Mergers and Divisions
Chapter 40. A Comprehensive Guide to Partnership Terminations, Including the Impact of the New Proposed Regulations
Chapter 41. Defining “Real Property” for REIT Purposes
Chapter 42. Taxation of Real Estate Investment Trusts (“REITs”)
Chapter 43. Dealer Sales Rules for Real Estate Investment Trusts
Chapter 44. Real Estate Investment Trust Corner—IRS Guidance on REIT Deficiency Dividends
Chapter 45. Real Estate Investment Trust Corner—Hotel REIT Rules and Recent Developments
Chapter 46. Mixed-Use Senior Living Communities
Chapter 47. Protecting OP Unitholders in REIT Going Private Transactions
Chapter 48. Negotiating Acquisitions Using OP Units
Chapter 49. Opportunities and Pitfalls for the Property Owner in Transactions with a REIT
Chapter 50. Real Estate Investment Trust Corner—Foreign Shareholders in Domestically Controlled REITs
Chapter 51. Investment in U.S. Real Estate by Sovereign Wealth Funds—Tax Issues
Chapter 52. New FIRPTA Proposals Would Encourage Foreign Investment in REITs
Chapter 53. Condominium Developers Can Avoid the Long-Term Contract Rules While Waiting for Code Sec. 460 Regulations
Chapter 54. New Ruling on Like-Kind Exchanges of Leveraged Property Solves Problems and Creates Opportunities
Chapter 55. Tax Issues in Defeasing a Conduit Loan, Including in a Like-Kind Exchange
Chapter 56. Capital Gains Planning
Chapter 57. Maximizing Capital Gains in Real Estate Transactions: Case Studies
Chapter 58. Disposition of Real Estate—Capital Gain vs. Ordinary Income
Chapter 59. Coping with CODI Under Prop. Regs. §1.108-8 and Code§108(i)
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, Other Purposes
Chapter 63. Real Estate Investment Trust Corner—Planning for COD Income
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. Real Estate Investment Trust Corner—Foreclosure Property Election
Chapter 71. Partnership Bankruptcy Tax Issues
Chapter 72. Chapter 8: The Trouble with Troubled Partnerships
Chapter 73. Final Partnership Debt-for-Equity Regs Deny Creditors’ Losses
Chapter 74. Revenue Ruling 2012-14: The IRS Lends a Helping Hand to Insolvent Partners
Chapter 75. The Tax Treatment of Environmental Cleanup Costs
Chapter 76. Recent Developments in Partnership Taxation (PowerPoint Slides)
Chapter 77. Creative Planning To Control Partnership Liability Allocations (PowerPoint Slides)
Chapter 78. Selected Tax Allocation Problems for Partnerships and LLCs (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. Extracting Equity on a Tax-Free Basis (PowerPoint Slides)
Chapter 82. Investments in United States Real Property by Non-U.S. Investors—U.S. Tax Considerations (PowerPoint Slides)
Chapter 83. Non-U.S. Investors Participating in Your U.S. Real Estate Deal (PowerPoint Slides)
Chapter 84. Current Issues in Like-Kind Exchanges (PowerPoint Slides)
Chapter 85. Partnerships and Disregarded Entities in Like-Kind Exchanges (PowerPoint Slides)
Chapter 86. Maximizing Capital Gains in Real Estate Transactions (PowerPoint Slides)
Chapter 87. Hot Topics in Like-Kind Exchanges (PowerPoint Slides)
Chapter 88. Leasing Issues (PowerPoint Slides)
Chapter 89. Capital Gains Planning (PowerPoint Slides)
Chapter 90. Disposing of Overleveraged Real Estate: Thinking Outside the Box (PowerPoint Slides)
Index
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