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Real Estate Tax Forum (Eighth Annual)
Chair(s):
Leslie H. Loffman, Sanford C. Presant, Blake D. Rubin
Practice Area:
Real estate,
Tax
Published:
Feb 2006
i
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ISBN:
1402407114
PLI Item #:
8364
CHB Spine #:
J692, J693, J694
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Table of Contents
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Front Matter
Table of Contents
Table of Contents
Table of Contents
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. 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. Jobs Act Tightens Partnership Tax Rules
Chapter 7. Dealing with the Service’s Interim Guidance on Downward Basis Adjustments Under 734 and 743
Chapter 8. IRS Bars Acquisition of Replacement Property from Related Parties— or Does It?
Chapter 9. Long-Awaited 469 Final Regs. on Self-Charged Items—Irs Holds The Line on Interest Only
Chapter 10. Broad Scope of Section 470 Catches Many Non-Abusive Transactions
Chapter 11. Joint Ventures with Tax-Exempt Entities and Taxable Operators (Including Reits)
Chapter 12. Tax Planning for the Property Owner in Reit Acquisitions
Chapter 13. Doing a Deal with a Reit: Upreits, Downreits and Other Structures (Slides)
Chapter 14. The Ups and Downs of Downreits
Chapter 15. Tax Treatment of REITS and REIT Shareholders
Chapter 16. Reit Mergers & Acquisitions; Tax Consequences
Chapter 17. New Ruling Permits Reits to Make Subordinated Loans
Chapter 18. Income Recognition Checklist for Property Contributions to Upreits and Other Partnerships
Chapter 19. Income Recognition Checklist (Problems)
Chapter 20. Effecting Tax-Free Property Contributions to Upreits and Other Partnerships
Chapter 21. Avoid Taxes for Property Contributions: Transferring to Upreits and Other Partnerships
Chapter 22. Avoiding Phantom Income Traps in Real Estate Llcs and Partnerships
Chapter 23. A Section 754 Paradox: Basis Step-Up Triggers Gain Recognition in Upreit and Other Partnership Contribution Transactions
Chapter 24. Partnership Mergers, the Anti-Mixing Bowl Rules and Rev. Rul. 2004-43: How Could The Service be so Wrong?
Chapter 25. IRS Creates Controversy in Rev. Rul. 2004-43
Chapter 26. Creative Transactional Planning Using The Partnership Merger and Division Regulations
Chapter 27. The History of Section 704(B)
Chapter 28. Rev. Rul. 99-43: When to Hold’Em, When to Fold’Em, and When to Book-Down
Chapter 29. Exploring The Outer Limits of Section 704(C)(1)(A)
Chapter 30. Take the Money and Run: Extracting Equity on a Tax-Free Basis
Chapter 31. Extracting Equity on a Tax-Free Basis (Slides)
Chapter 32. Final Partnership Liability Regulations Target “Son of Boss” Abuse but Sweep More Broadly
Chapter 33. Guarantees, Dros and Ccos: Getting Partnership Liability Allocations Right
Chapter 34. Allocation of Nonrecourse Liabilites: IRS Takes Two Steps Forward, One Back
Chapter 35. Allocating Partnership Liabilities Under Section 752 of the Internal Revenue Code
Chapter 36. New Ruling on Allocating Partnership Liabilities Disregards Technicalities to Absolve Taxpayer of Gain
Chapter 37. Supreme Court Hands Taxpayers a Victory in Gitlitz, But Will Congress Take it Away?
Chapter 38. New Decision Casts a Shadow on the Contested Liability Exception to Cod Income
Chapter 39. Briarpark and the Unexpected Limits to Careful Tax Planning
Chapter 40. Unsecured Borrowing Treated as Qualified Nonrecourse Financing Under Code Secs. 752 and 465
Chapter 41. IRS Issues Taxpayer-Friendly Qualified Nonrecourse Financing Regs
Chapter 42. Taxation of Real Estate Investment Trusts (“Reits”)
Chapter 43. Recent Developments Regarding Disguised Sales of Partnership Interests
Chapter 44. Disguised Sales of Partnership Interests: An Analysis of the Proposed Regulations
Chapter 45. Controversial Prop. Regs. on Disguised Sales of Partnership Interests—Irs Jumps Into the Deep End
Chapter 46. Real Estate Investment Trusts: A Guide to their History, Formation and Taxation
Chapter 47. Dealer Sales Rules for Real Estate Investment Trusts
Chapter 48. Tax Strategies to Deal with Real Estate Workouts (Slides)
Chapter 49. Real Estate Workouts—a Step by Step Analysis
Chapter 50. Tax Aspects of Real Estate Workouts.
Chapter 51. 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 52. Creative Strategies for the Disposition of Overleveraged Real Estate (Slides)
Chapter 53. Tax Planning for the Sale or Other Disposition of Overencumbered Real Estate
Chapter 54. Final Section 467 Regulations Present Problems and Opportunities
Chapter 55. Tax Treatment of Environmental Remediation Costs
Chapter 56. Tax Treatment of Environmental Cleanup Costs
Chapter 57. Maximizing Capital Gains in Real Estate Transactions: Case Studies
Chapter 58. Maximizing Capital Gains in Real Estate Transactions (Slides)
Chapter 59. Chapter 59
Chapter 60. New Proposed Regulations on Mergers Involving Disregarded Entities
Chapter 61. Investment in Real Estate by Tax-Exempt Investors
Chapter 62. Maximizing Capital Gains in Real Estate Transactions: Case Studies
Chapter 63. Proposed Regulations on Allocating Partnership Liabilities to Owners of Disregarded Entities
Chapter 64. Disposition of Real Estate—Capital Gain vs. Ordinary Income
Chapter 65. Preserving Capital Gains in Real Estate Transactions.
Chapter 66. Critical Partnership Tax Issues—an Overview
Chapter 67. Proposed Regulations on Partnership Interests Issued for Services: Practical Problems and Opportunities
Chapter 68. Choice of Entity—Business and Tax Considerations
Chapter 69. Final PTP Regs. Abandon Restrictive Conditions and Adopt Workable New Exemptions
Chapter 70. Tax Aspects of the Initial Partnership or LLC Negotiation
Chapter 71. Negotiating Acquisitions Using OP Units
Chapter 72. Final Allocation Regulations Add Simplicity but Retain Planning Opportunities
Chapter 73. Creative Planning to Control Partnership Liability Allocations
Chapter 74. Creative Planning to Control Partnership Liability Allocations (Slides)
Chapter 75. New Regulations Regarding Assumption of Partnership Liabilities
Chapter 76. The Proposed Regulations on Partnership Allocations with Respect to Contributed Property
Chapter 77. Selected Tax Allocation Problems for Partnerships and LLCS (Slides)
Chapter 78. Selected Operating Agreement Tax Allocation Provisions for Limited Liability Companies
Chapter 79. Tax Issues Raised by Partnership Options
Chapter 80. Tax Primer for Partnership Workouts
Chapter 81. Important Tax Developments Affecting Partnership Workouts
Chapter 82. A Comprehensive Guide to Partnership Terminations, Including the Impact of the New Proposed Regulations
Chapter 83. Planning for the Termination of an Interest in a Partnership—Withdrawals, Distributions and Other Exit Strategies
Chapter 84. Estate Planning with Real Estate Assets
Chapter 85. Foreign Investment in us Real Estate
Chapter 86. Fundamentals of Taxation of Foreign Investors (Slides)
Chapter 87. Opportunities for the Foreign Investor in United States Real Estate —If Planning Comes First
Chapter 88. Hot Topics Involving Like-Kind Exchanges
Chapter 89. The ‘State of the Art’ in Like-Kind Exchanges— Revisited
Chapter 90. New Ruling on Like-Kind Exchanges of Leveraged Property Solves Problems and Creates Opportunities
Chapter 91. Current Issues in Like-Kind Exchanges (Slides)
Chapter 92. Partnerships and Disregarded Entities in Like-Kind Exchanges (Slides)
Chapter 93. A New Twist to Reducing Tax Bills on Home Sales: Revenue Procedure Loosens Up Restrictions on Like Kind Exchanges
Chapter 94. New Revenue Procedure on Reverse Like-Kind Exchanges Replaces Tax Risk with Tax Certainty
Chapter 95. New Rules Likely to Increase Use of Tenancy-In-Common Ownership in Like-Kind Exchanges
Chapter 96. Multi-Year Deferred Like-Kind Exchanges by Partnerships—is the New Rev. Rul. A Trojan Horse?
Chapter 97. DSTS and § 1031: A Marriage Made in Heaven, or Just a Pipe Dream?
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