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Real Estate Tax Forum (Seventh Annual)
Chair(s):
Leslie H. Loffman, Sanford C. Presant, Blake D. Rubin
Practice Area:
Real estate,
Tax
Published:
Feb 2005
i
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ISBN:
140240557X
PLI Item #:
6155
CHB Spine #:
J644, J645, J646
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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. New Disclosure and Listing Regulations Promise Headache for Everyone
Chapter 3. Final Corporate Tax Shelter Disclosure and List Maintenance Regulations Impose Burdens on Everyone
Chapter 4. When is a Partner Not a Partner?
Chapter 5. Here Comes the Kitchen Sink: IRS Throws "Everything but" at Two Partnership Tax Deferral Structures
Chapter 6. IRS Bars Acquisition of Replacement Property From Related Parties - Or Does It?
Chapter 7. Long-Awaited 469 Final Regs. On Self-Charged Items-IRS Holds the Line on Interest Only
Chapter 8. Joint Ventures with REITs and Tax-Exempt Entities
Chapter 9. Tax Planning for the Property Owner in REIT Acquisitions
Chapter 10. Doing A Deal With A REIT: UPREITS, DownREITS and Other Structures (Slides)
Chapter 11. The Ups and Downs of DownREITs
Chapter 12. Tax Treatment of REITs and REIT Shareholders
Chapter 13. REIT Mergers & Acquisitions: Tax Consequences
Chapter 14. New Ruling Permits REITS to Make Subordinated Loans
Chapter 15. Income Recognition Checklist for Property Contributions to UPREITS and Other Partnerships
Chapter 16. Income Recognition Checklist (Problems)
Chapter 17. Effecting Tax-Free Property Contributions to UPREITs and Other Partnerships
Chapter 18. Avoid Taxes for Property Contributions: Transferring to UPREITs and Other Partnerships
Chapter 19. Avoiding Phantom Income Traps in Real Estate LLCs and Partnerships
Chapter 20. A Section 754 Paradox: Basis Step-Up Triggers Gain Recognition in UPREIT and Other Partnership Contribution Transactions
Chapter 21. Partnership Mergers, The Anti-Mixing Bowl Rules and Rev. Rul. 2004-43: How Could the Service be So Wrong?
Chapter 22. IRS Creates Controversy in Rev. Rul. 2004-43
Chapter 23. Creative Transactional Planning Using the Partnership Merger and Division Regulations
Chapter 24. The History of Section 704(b)
Chapter 25. Rev. Rul. 99-43: When to Hold'em, When to Fold'em, and When to Book-Down
Chapter 26. Exploring the Outer Limits of Section 704(c)(1)(A)
Chapter 27. Take the Money and Run: Extracting Equity on a Tax-Free Basis
Chapter 28. Extracting Equity on a Tax-Free Basis (Slides)
Chapter 29. New Partnership Liability Regulations Target Abuse But Sweep More Broadly
Chapter 30. Guarantees, DROs and CCOs: Getting Partnership Liability Allocations Right
Chapter 31. Allocation of Nonrecourse Liabilities: IRS Takes Two Steps Forward, One Back
Chapter 32. Allocating Partnership Liabilities Under Section 752 of the Internal Revenue Code
Chapter 33. New Ruling on Allocating Partnership Liabilities Disregards Technicalities to Absolve Taxpayer of Gain
Chapter 34. Supreme Court Hands Taxpayers a Victory in Gitlitz, But Will Congress Take It Away?
Chapter 35. New Decision Casts a Shadow on the Contested Liability Exception to COD Income
Chapter 36. Briarpark and the Unexpected Limits to Careful Tax Planning
Chapter 37. Unsecured Borrowing Treated as Qualified Nonrecourse Financing Under Code Secs, 752 and 465
Chapter 38. IRS Issues Taxpayer-Friendly Qualified Nonrecourse Financing Regs
Chapter 39. Taxation of Real Estate Investment Trusts ("REITS")
Chapter 40. Recent Developments Regarding Disguised Sales of Partnership Interests
Chapter 41. Real Estate Investment Trusts: A Guide to Their History, Formation and Taxation
Chapter 42. Dealer Sales Rules for Real Estate Investment Trusts
Chapter 43. Bankruptcy and Workouts: What the Tax Practitioner Need to Know (Slides)
Chapter 44. Real Estate Workouts - A Step-By-Step Analysis
Chapter 45. Tax Aspects of Real Estate Workouts
Chapter 46. Partnership Bankruptcy Tax Issues
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 (Slides)
Chapter 49. Tax Planning for the Sale or Other Dispositions of Overencumbered Real Estate
Chapter 50. Final Section 467 Regulations Present Problems and Opportunities
Chapter 51. Tax Treatment of Environmental Remediation Costs
Chapter 52. The Tax Treatment of Environmental Cleanup Costs
Chapter 53. Maximizing Capital Gains in Real Estate Transactions: Case Studies
Chapter 54. Maximizing Capital Gains in Real Estate Transactions (Slides)
Chapter 55. Capital Gains Planning (Slides)
Chapter 56. New Proposed Regulations on Mergers Involving Disregarded Entities
Chapter 57. Investment in Real Estate by Tax-Exempt Investors
Chapter 58. Maximizing Capital Gains in Real Estate Transactions: Case Studies
Chapter 59. Proposed Regulations on Allocating Partnership Liabilities to Owners of Disregarded Entities
Chapter 60. Disposition of Real Estate - Capital Gain vs. Ordinary Income
Chapter 61. Preserving Capital Gains in Real Estate Transactions
Chapter 62. Critical Partnership Tax Issues -- An Overview
Chapter 63. Choice of Entity -- Business and Tax Considerations
Chapter 64. Final PTP Regs. Abandon Restrictive Conditions and Adopt Workable New Exemptions
Chapter 65. Tax Aspects of the Initial Partnership or LLC Negotiation
Chapter 66. Negotiating Acquisitions Using OP Units
Chapter 67. Final Allocation Regulations Add Simplicity but Retain Planning Opportunities
Chapter 68. Creative Planning to Control Partnership Liability Allocations
Chapter 69. Creative Planning to Control Partnership Liability Allocations (Slides)
Chapter 70. New Regulations Regarding Assumption of Partnership Liabilities
Chapter 71. The Proposed Regulations on Partnership Allocations with Respect to Contributed Property
Chapter 72. Selected Tax Allocation Problems for Partnerships and LLCs (Slides)
Chapter 73. Selected Operating Agreement Tax Allocation Provisions for Limited Liability Companies
Chapter 74. Tax Issues Raised by Partnership Options
Chapter 75. Tax Primer for Partnership Workouts
Chapter 76. Important Tax Developments Affecting Partnership Workouts
Chapter 77. A Comprehensive Guide to Partnership Terminations, Including the Impact of the New Proposed Regulations
Chapter 78. Planning for the Termination of an Interest in a Partnership -- Withdrawals, Distributions and Other Exit Strategies
Chapter 79. Estate Planning with Real Estate Assets
Chapter 80. Fundamentals of Taxation of Foreign Investors (Slides)
Chapter 81. Opportunities for the Foreign Investor in United States Real Estate -- If Planning Comes First
Chapter 82. The "State of the Art" in Like-Kind Exchanges — Revisited
Chapter 83. New Ruling on Like-Kind Exchanges of Leveraged Property Solves Problems and Creates Opportunites
Chapter 84. Current Issues in Like-Kind Exchanges (Slides)
Chapter 85. Partnerships and Disregarded Entities in Like-Kind Exchanges (Slides)
Chapter 86. New Revenue Procedure on Reverse Like-Kind Exchanges Replaces Tax Risk with Tax Certainty
Chapter 87. New Rules Likely to Increase Use of Tenancy-in-Common Ownership in Like-Kind Exchanges
Chapter 88. Multi-Year Deferred Like-Kind Exhanges by Partnerships -- Is the New Rev. Rul. a Trojan Horse?
Chapter 89. DSTS and Sec. 1031: A Marriage Made in Heaven, or Just a Pipe Dream?
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