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Real Estate Tax Forum (17th Annual)
Chair(s):
Sanford C. Presant, Blake D. Rubin, Leslie H. Loffman
Practice Area:
Real Estate, Tax
Published:
Feb 2015
ISBN:
9781402423567
PLI Item #:
58233
CHB Spine #:
D423, D424, D425
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 (October 1, 2014)
Chapter 2. Developments in Partnership and Real Estate Taxation in 2014 (September 1, 2014)
Chapter 3. Developments in Partnership and Real Estate Taxation in 2013
Chapter 4. Developments in Partnership and Real Estate Taxation in 2012
Chapter 5. Developments in Partnership and Real Estate Taxation in 2011
Chapter 6. Developments in Partnership and Real Estate Taxation in 2010
Chapter 7. Jobs Act Tightens Partnership Tax Rules
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. A Section 754 Paradox: Basis Step-Up Triggers Gain Recognition in UPREIT and Other Partnership Contribution Transactions
Chapter 15. Proposed Regulations on Allocating Partnership Liabilities to Owners of Disregarded Entities
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. Take the Money and Run: Extracting Equity on a Tax-Free Basis
Chapter 20. Final Partnership Liability Regulations Target “Son of Boss” Abuse But Sweep More Broadly
Chapter 21. 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 22. Sixth Circuit Vacates Controversial Hubert Case Dealing with Partner’s At-Risk Amount
Chapter 23. Tax Court Sticks to its Guns and Sticks it to Taxpayers in Hubert Case
Chapter 24. New Regulations Regarding Assumption of Partnership Liabilities
Chapter 25. The Proposed Regulations on Partnership Allocations with Respect to Contributed Property
Chapter 26. New Ruling on Allocating Partnership Liabilities Disregards Technicalities to Absolve Taxpayer of Gain
Chapter 27. Planning for Partnership Liability Allocations, Including the New Proposed Regulations (September 2014)
Chapter 28. Final and Proposed Regualtions Regarding Partnership Noncompensatory Options (January, 2014)
Chapter 29. Testimony Before the Subcommittee on Select Revenue Measures (May 15, 2013)
Chapter 30. IRS Stretches to Help a Taxpayer in New Disguised Sale Private Letter Ruling
Chapter 31. Partnership Disguised Sales of Property: G-I Holdings Misses the Mark
Chapter 32. Tax Court Goes Overboard in Canal
Chapter 33. Implications of Canal Corporation for Structuring Partnership Transactions
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. New Proposed Regulations on Mergers Involving Disregarded Entities
Chapter 39. Partnership Mergers, The Anti-Mixing Bowl Rules and Rev. Rul. 2004-43: How Could the Service be So Wrong?
Chapter 40. Proposed Regulations on Application of the Anti-Mixing Bowl Rules After a Partnership Merger to Apply Prospectively
Chapter 41. Handling Partnership Mergers and Divisions
Chapter 42. A Comprehensive Guide to Partnership Terminations, Including the Impact of the New Proposed Regulations
Chapter 43. Defining “Real Property” for REIT Purposes
Chapter 44. Taxation of Real Estate Investment Trusts (“REITS”)
Chapter 45. Dealer Sales Rules for Real Estate Investment Trusts
Chapter 46. Real Estate Investment Trust Corner—IRS Guidance on REIT Deficiency Dividends
Chapter 47. Real Estate Investment Trust Corner—Hotel REIT Rules and Recent Developments
Chapter 48. Mixed-Use Senior Living Communities
Chapter 49. Protecting OP Unitholders in REIT Going Private Transactions
Chapter 50. Negotiating Acquisitions Using OP Units
Chapter 51. Opportunities and Pitfalls for the Property Owner in Transactions with a REIT
Chapter 52. Real Estate Investment Trust Corner—Foreign Shareholders in Domestically Controlled REITs
Chapter 53. Investment in U.S. Real Estate by Sovereign Wealth Funds—Tax Issues
Chapter 54. New FIRPTA Proposals Would Encourage Foreign Investment in REITs
Chapter 55. Condominium Developers Can Avoid the Long-Term Contract Rules While Waiting for Code Sec. 460 Regulations
Chapter 56. New Ruling on Like-Kind Exchanges of Leveraged Property Solves Problems and Creates Opportunities
Chapter 57. Tax Issues in Defeasing a Conduit Loan, Including in a Like-Kind Exchange
Chapter 58. Capital Gains Planning
Chapter 59. Maximizing Capital Gains in Real Estate Transactions: Case Studies
Chapter 60. Disposition of Real Estate—Capital Gain vs. Ordinary Income
Chapter 61. Coping with CODI Under Prop. Regs. §1.108-8 and Code §108(I)
Chapter 62. Cancellation of Indebtedness Income Deferral In Economic Stimulus Bill Raises Complex Issues for Partnerships
Chapter 63. Rev. Proc. 2009-37 Allows Flexibility for Partnerships Electing New C.O.D. Income Deferral
Chapter 64. Recourse or Nonrecourse: Liability Treatment for COD and Other Purposes
Chapter 65. Real Estate Investment Trust Corner—Planning for COD Income
Chapter 66. Debt Workouts: The Partnership and the Partners
Chapter 67. Tax Primer for Partnership Workouts
Chapter 68. Important Tax Developments Affecting Partnership Workouts
Chapter 69. Tax Aspects of Real Estate Workouts
Chapter 70. Creditors Beware: Proposed Partnership Debt-For-Equity Regulations Deny Your Tax Loss
Chapter 71. Tax Planning for the Sale or Other Disposition of Overencumbered Real Estate
Chapter 72. Real Estate Investment Trust Corner—Foreclosure Property Election
Chapter 73. Partnership Bankruptcy Tax Issues
Chapter 74. Chapter 8: The Trouble with Troubled Partnerships
Chapter 75. Final Partnership Debt-for-Equity Regs Deny Creditors’ Losses
Chapter 76. Revenue Ruling 2012-14: The IRS Lends a Helping Hand to Insolvent Partners
Chapter 77. The Tax Treatment of Environmental Cleanup Costs
Chapter 78. Recent Developments in Partnership and Real Estate Taxation (PowerPoint slides)
Chapter 79. Creative Planning for Partnership Liability Allocations, Including the New Proposed Regulations (PowerPoint slides)
Chapter 80. Selected Tax Allocation Problems for Partnerships and LLCs (PowerPoint slides)
Chapter 81. Allocation Examples (PowerPoint slides)
Chapter 82. Tax Provision Issues Checklist for LLC and Partnership Agreements (PowerPoint slides)
Chapter 83. Handling UPREIT and DownREIT Transactions: Latest Techniques and Issues (PowerPoint slides)
Chapter 84. Making Section 704(c) Work For You (PowerPoint slides)
Chapter 85. Extracting Equity on a Tax-Free Basis (PowerPoint slides)
Chapter 86. Investments in United States Real Property By Non-U.S. Investors—U.S. Tax Considerations (PowerPoint slides)
Chapter 87. Non-U.S. Investors Participating in Your U.S. Real Estate Deal (PowerPoint slides)
Chapter 88. Current Issues in Like-Kind Exchanges (PowerPoint slides)
Chapter 89. Partnerships and Disregarded Entities in Like-Kind Exchanges (PowerPoint slides)
Chapter 90. Maximizing Capital Gains in Real Estate Transactions (PowerPoint slides)
Chapter 91. Hot Topics in Like-Kind Exchange Issues (PowerPoint slides)
Chapter 92. Leasing Issues (PowerPoint slides)
Chapter 93. Capital Gains Planning (PowerPoint slides)
Chapter 94. Disposing of Overleveraged Real Estate: Thinking Outside the Box (PowerPoint slides)
Index
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