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20th Annual Real Estate Tax Forum
Author(s):
Leslie H. Loffman, Sanford C. Presant, Blake D. Rubin
Practice Area:
Real Estate, Tax
Published:
Feb 2018
ISBN:
9781402430565
PLI Item #:
218811
CHB Spine #:
D505, D506, D507
Terms & Connectors
Natural Language
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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 (September 27, 2017)
Chapter 2. Developments in Partnership and Real Estate Taxation in 2016 (September 1, 2016)
Chapter 3. Developments in Partnership and Real Estate Taxation in 2015 (October 1, 2015)
Chapter 4. Developments in Partnership and Real Estate Taxation in 2014 (September 1, 2014)
Chapter 5. Developments in Partnership and Real Estate Taxation in 2013 (September 15, 2013)
Chapter 6. Jobs Act Tightens Partnership Tax Rules
Chapter 7. Tax Planning for Partnership Options and Compensatory Equity Interests (September 1, 2008)
Chapter 8. Joint Ventures with Tax Exempt Entities and Taxable Operators (Including REITs)
Chapter 9. Choice of Entity—Business and Tax Considerations
Chapter 10. Tax Aspects of the Initial Partnership or LLC Negotiation
Chapter 11. Selected Operating Agreement Tax Allocation Provisions for Limited Liability Companies
Chapter 12. Income Recognition Checklist (Problems)
Chapter 13. Proposed Regulations on Allocating Partnership Liabilities to Owners of Disregarded Entities
Chapter 14. Put a “Bottom” Deficit Restoration Obligation in Your Partnership Liability Allocation Tool Box (September 1, 2014)
Chapter 15. New Temporary and Proposed Partnership Liability Allocation Regulations Are Deeply Flawed and Should Be Withdrawn (February 1, 2017)
Chapter 16. Final Regulations on the Treatment of Disregarded Entities for Purposes of Characterizing and Allocating Liabilities Under Code Sec. 752: Questions and Complexities Continue
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. Final Partnership Liability Regulations Target “Son of Boss” Abuse But Sweep More Broadly
Chapter 20. 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 21. Sixth Circuit Vacates Controversial Hubert Case Dealing with Partner’s At-Risk Amount
Chapter 22. Tax Court Sticks to Its Guns and Sticks It to Taxpayers in Hubert Case
Chapter 23. New Regulations Regarding Assumption of Partnership Liabilities
Chapter 24. The Proposed Regulations on Partnership Allocations with Respect to Contributed Property
Chapter 25. New Ruling on Allocating Partnership Liabilities Disregards Technicalities to Absolve Taxpayer of Gain
Chapter 26. Planning for Partnership Liability Allocations, Including the New Proposed Regulations (January 2015)
Chapter 27. Final and Proposed Regulations Regarding Partnership Noncompensatory Options (January 2014)
Chapter 28. Testimony Before the Subcommittee on Select Revenue Measures (May 15, 2013)
Chapter 29. New Taxpayer Favorable PLRs Allow Gain on Sale of Partnership Assets to Be Offset by Disallowed Loss on Earlier Sale of Partnership Interest (April 2016)
Chapter 30. New Partnership Disguised Sale Regulations End Leveraged Partnerships (June 1, 2017)
Chapter 31. Partnership Disguised Sales of Property: G-I Holdings Misses the Mark (March 15, 2010)
Chapter 32. Tax Court Goes Overboard in Canal (January 10, 2011)
Chapter 33. Implications of Canal Corporation for Structuring Partnership Transactions (September 15, 2013)
Chapter 34. Recent Developments Regarding Disguised Sales of Partnership Interests
Chapter 35. Disguised Sales of Partnership Interests: An Analysis of the Proposed Regulations
Chapter 36. Tax Court Respects Partnership’s Property Distribution: Countryside Limited Partnership v. Commissioner
Chapter 37. Proposed Regulations on Partnership Interests Issued for Services Create Problems and Opportunities
Chapter 38. Is Your Transaction a Partnership Merger or Liquidation and Why You Should Care (January 2015)
Chapter 39. New Proposed Regulations on Mergers Involving Disregarded Entities
Chapter 40. Partnership Mergers, the Anti-Mixing Bowl Rules and Rev. Rul. 2004-43: How Could the Service Be So Wrong?
Chapter 41. Proposed Regulations on Application of the Anti-Mixing Bowl Rules After a Partnership Merger to Apply Prospectively
Chapter 42. Handling Partnership Mergers and Divisions (December 2013)
Chapter 43. A Comprehensive Guide to Partnership Terminations, Including the Impact of the New Proposed Regulations
Chapter 44. Partnership Equity Extraction Techniques (September 1, 2015)
Chapter 45. Taxation of Real Estate Investment Trusts (“REITs”)
Chapter 46. Dealer Sales Rules for Real Estate Investment Trusts
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 (October 2012)
Chapter 50. A Section 754 Paradox: Basis Step-Up Triggers Gain Recognition in UPREIT and Other Partnership Contribution Transactions
Chapter 51. Can Code Sec. 704(c) Be Applied to a Capital Gain Dividend Paid by a REIT? (October 1, 2017)
Chapter 52. New Ruling on Like-Kind Exchanges of Leveraged Property Solves Problems and Creates Opportunities
Chapter 53. Defeasing Conduit Loans: Tax Issues, Premiums, Like-Kind Exchanges and “New York Style” (May 2015)
Chapter 54. Capital Gains Planning
Chapter 55. Maximizing Capital Gains in Real Estate Transactions: Case Studies
Chapter 56. Disposition of Real Estate—Capital Gain vs. Ordinary Income
Chapter 57. Rev. Rul. 2016-15 Holds Real Estate Dealers Cannot Exclude Cancellation of Indebtedness Income, But Is It Correct?
Chapter 58. “Bad Boy” Nonrecourse Carve-Outs in Real Estate Loan Cause It to Be Recourse—Or Do They? (May 2016)
Chapter 59. Cancellation of Indebtedness Income Deferral in Economic Stimulus Bill Raises Complex Issues for Partnerships (July 1, 2009)
Chapter 60. Rev. Proc. 2009-37 Allows Flexibility for Partnerships Electing New C.O.D. Income Deferral (September 22, 2009)
Chapter 61. Recourse or Nonrecourse: Treatment of Liabilities for COD and Other Purposes (September 13, 2010)
Chapter 62. Is It Cancellation of Debt (COD) Income?: New IRS Chief Counsel Advice Takes the Gas Out of Great Plains Gasification (September 1, 2015)
Chapter 63. Tax Primer for Partnership Workouts
Chapter 64. Important Tax Developments Affecting Partnership Workouts
Chapter 65. Tax Aspects of Real Estate Workouts
Chapter 66. Creditors Beware: Proposed Partnership Debt-for-Equity Regulations Deny Your Tax Loss (March 1, 2009)
Chapter 67. Tax Planning for the Sale or Other Disposition of Overencumbered Real Estate
Chapter 68. Partnership Bankruptcy Tax Issues
Chapter 69. Final Partnership Debt-for-Equity Regs Deny Creditors’ Losses (February 27, 2012)
Chapter 70. Revenue Ruling 2012-14: The IRS Lends a Helping Hand to Insolvent Partners (July 2, 2012)
Chapter 71. The Tax Treatment of Environmental Cleanup Costs
Chapter 72. Creative Planning for Partnership Liability Allocations, Including the New Proposed Regulations (PowerPoint slides)
Chapter 73. Selected Tax Allocation Problems for Partnerships and LLCs (PowerPoint slides)
Chapter 74. Tax Provision Issues Checklist for LLC and Partnership Agreements (PowerPoint slides)
Chapter 75. Handling UPREIT and DownREIT Transactions: Latest Techniques and Issues (PowerPoint slides)
Chapter 76. Making Section 704(c) Work for You (PowerPoint slides)
Chapter 77. Current Issues in Like-Kind Exchanges (PowerPoint slides)
Chapter 78. Partnerships and Disregarded Entities in Like-Kind Exchanges (PowerPoint slides)
Chapter 79. Maximizing Capital Gains in Real Estate Transactions (PowerPoint slides)
Chapter 80. Hot Like-Kind Exchange Issues (PowerPoint slides)
Chapter 81. Leasing Issues (PowerPoint slides)
Chapter 82. Capital Gains Planning (PowerPoint slides)
Chapter 83. Disposing of Overleveraged Real Estate: Thinking Outside the Box (PowerPoint slides)
Chapter 84. Workouts & Debt Restructurings (PowerPoint slides)
Index
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