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Real Estate Tax Forum (Twelfth Annual)
Chair(s):
Blake D. Rubin, Leslie H. Loffman, Sanford C. Presant
Practice Area:
Real estate,
Real estate investment trusts,
Real estate limited partnerships,
Real estate taxes,
Real property taxes,
Tax
Published:
Dec 2009
i
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ISBN:
9781402413230
PLI Item #:
23601
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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. Recent Developments in Partnership Taxation
Chapter 3. Jobs Act Tightens Partnership Tax Rules
Chapter 4. Working with the Partnership Liability Allocation Rules: Guarantees, DROs and More
Chapter 5. Tax Planning for Partnership Options and Compensatory Equity Interests
Chapter 6. Joint Ventures with Tax-Exempt Entities and Taxable Operators (Including REITs)
Chapter 7. Taxation of Real Estate Investment Trusts (“REITs”)
Chapter 8. Dealer Sales Rules for Real Estate Investment Trusts
Chapter 9. Protecting OP Unitholders in REIT Going Private Transactions
Chapter 10. REIT Update
Chapter 11. REIT Mergers & Acquisitions: Tax Consequences
Chapter 12. REIT Structuring: The Challenges and the Possibilities
Chapter 13. Comments in Response to IRS Announcement 2008-115
Chapter 14. Request for Guidance on the Treatment of Interests in Money Market Mutual Funds Under Section 856(c)(4)(A)
Chapter 15. Elective Stock Dividends/Extension and Amplification of Rev. Proc. 2009-15
Chapter 16. Negotiating Acquisitions Using OP Units
Chapter 17. Handling UPREIT and Downreit Transactions: Latest Techniques and Issues
Chapter 18. Income Recognition Checklist (Problems)
Chapter 19. Avoid Taxes for Property Contributions: Transferring to UPREITs and Other Partnerships
Chapter 20. A Section 754 Paradox: Basis Step-Up Triggers Gain Recognition in UPREIT and Other Partnership Contribution Transactions
Chapter 21. Proposed Regulations on Allocating Partnership Liabilities to Owners of Disregarded Entities
Chapter 22. Final Regulations on the Treatment of Disregarded Entities for Purposes of Characterizing and Allocating Liabilities Under Code Sec. 752: Questions and Complexities Continue
Chapter 23. Rev. Rul. 99-43: When to Hold’em, when to Fold’em, and when to Book-Down
Chapter 24. Maintenance of Section 704(c) Layers and Partnership Mergers and Divisions Comments in Response to Notice 2009-70
Chapter 25. Exploring the Outer Limits of Section 704(c)(1)(A)
Chapter 26. Take the Money and Run: Extracting Equity on a Tax-Free Basis
Chapter 27. Final Partnership Liability Regulations Target "Son of Boss" Abuse But Sweep More Broadly
Chapter 28. 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 29. Sixth Circuit Vacates Controversial Hubert Case Dealing with Partner's At-Risk Amount
Chapter 30. Tax Court Sticks to Its Guns and Sticks It to Taxpayers in Hubert Case
Chapter 31. New Regulations Regarding Assumption of Partnership Liabilities
Chapter 32. The Proposed Regulations on Partnership Allocations with Respect to Contributed Property
Chapter 33. New Ruling on Allocating Partnership Liabilities Disregards Technicalities to Absolve Taxpayer of Gain
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. Estate Planning for Real Estate Entrepreneurs
Chapter 39. New Ruling on Like-Kind Exchanges of Leveraged Property Solves Problems and Creates Opportunities
Chapter 40. Tax Issues in Defeasing a Conduit Loan, Including in a Like-Kind Exchange
Chapter 41. Choice of Entity--Business and Tax Considerations
Chapter 42. Tax Aspects of the Initial Partnership or LLC Negotiation
Chapter 43. Selected Operating Agreement Tax Allocation Provisions for Limited Liability Companies
Chapter 44. Capital Gains Planning
Chapter 45. Maximizing Capital Gains in Real Estate Transactions: Case Studies
Chapter 46. Disposition of Real Estate--Capital Gain vs. Ordinary Income
Chapter 47. New Proposed Regulations on Mergers Involving Disregarded Entities
Chapter 48. Partnership Mergers, the Anti-Mixing Bowl Rules and Rev. Rul. 2004-43: How Could The Service Be So Wrong?
Chapter 49. Proposed Regulations on Application of the Anti-Mixing Bowl Rules After a Partnership Merger to Apply Prospectively
Chapter 50. Creative Transactional Planning Using the Partnership Merger and Division Regulations
Chapter 51. A Comprehensive Guide to Partnership Terminations, Including the Impact of the New Proposed Regulations
Chapter 52. The Tax Treatment of Environmental Cleanup Costs
Chapter 53. Investment in U.S. Real Estate by Sovereign Wealth Funds--Tax Issues
Chapter 54. IRS Clarifies Tax Treatment of Foreign Governments Investing in REITs, Highlighting Tax Planning Opportunities
Chapter 55. Planning for Discharge of Indebtedness
Chapter 56. Coping with CODI Under Prop. Regs. Section 1.108-8 and Code Section 108(i)
Chapter 57. Cancellation of Indebtedness Income Deferral in Economic Stimulus Bill Raises Complex Issues for Partnerships
Chapter 58. Rev. Proc. 2009-37 Allows Flexibility for Partnerships Electing New C.O.D. Income Deferral
Chapter 59. Tax Primer for Partnership Workouts
Chapter 60. Important Tax Developments Affecting Partnership Workouts
Chapter 61. Tax Aspects of Real Estate Workouts
Chapter 62. Creditors Beware: Proposed Partnership Debt-for-Equity Regulations Deny Your Tax Loss
Chapter 63. Real Estate Debt Workouts in 2008--The Rules Have Changed
Chapter 64. Tax Planning for the Sale or Other Disposition of Overencumbered Real Estate
Chapter 65. Handling UpREIT and DownREIT Transactions: Latest Techniques and Issues (PowerPoint)
Chapter 66. Extracting Equity on a Tax-Free Basis (PowerPoint)
Chapter 67. Creative Planning to Control Partnership Liability Allocations (PowerPoint)
Chapter 68. Selected Tax Allocation Problems for Partnerships and LLCs (PowerPoint)
Chapter 69. FIRPTA Problem
Chapter 70. Like-Kind Exchanges (PowerPoint)
Chapter 71. Current Issues in Like-Kind Exchanges (PowerPoint)
Chapter 72. Partnerships and Disregarded Entities in Like-Kind Exchanges (PowerPoint)
Chapter 73. Maximizing Capital Gains in Real Estate Transactions (PowerPoint)
Chapter 74. Capital Gains Planning (PowerPoint)
Chapter 75. Foreign Investment in US Real Estate (PowerPoint)
Chapter 76. Fundamentals of Taxation of Foreign Investors (PowerPoint)
Chapter 77. Workouts and Cancellation of Indebtedness Income
Chapter 78. Dealing with Financially Distressed Real Estate Understanding the Tax Issues
Chapter 79. Creative Strategies for the Disposition of Overleveraged Real Estate (PowerPoint)
Index to Vol. 1
Index to Vol. 2
Index to Vol. 3
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