On-Demand   On-Demand Web Programs

21st Annual Real Estate Tax Forum

Released on: Feb. 4, 2019
Running Time: 09:59:03
Our 21st Anniversary program will continue to focus on transactions, highlighting the tax problems encountered by practitioners in today’s typical commercial real estate transactions and structures, and examining the simple and sophisticated solutions being used by the experts.  Panels of nationally-recognized real estate tax experts from major law and accounting firms will provide attorneys, accountants and real estate professionals with a detailed analysis of the most cutting-edge and creative tax planning techniques available for structuring, restructuring and unwinding different types of real estate transactions in today’s challenging environment post-2017 Tax Act environment.  Using extensive visual aids and actual deal structures, this group of entertaining, experienced and knowledgeable speakers will share their experiences with today’s state-of-the-art planning techniques, and emphasize practical approaches to solving difficult tax issues affecting real estate investment and operation.  

This Forum is designed for tax attorneys, accountants and real estate professionals who structure real estate transactions.

Topics Include
  • The latest developments in real estate taxation and partnership taxation (legislative, administrative and judicial), including:
    • Impact of the 2017 Tax Act on real estate, including any new regulatory and administrative guidance and technical corrections
    • Critical new regulations on bottom dollar guarantees and the allocation of partnership liabilities that are changing how deals get done
    • Drafting partnership agreements to deal with the new partnership audit rules
    • New key changes to the partnership disguised sale regulations that again allow leveraged partnerships but also affect many other transactions
  • Using “tiered partnerships” and “series LLCs”; structuring to maximize capital gain; strategies for avoiding income recognition traps and minimizing taxes under Sections 704(b), 704(c), 707, 737 and 752
  • Simplified approaches for drafting effective tax provisions for partnership and LLC agreements, including book-ups for service partners
  • Like-kind exchange developments, including tenancies-in-common, build-to-suit, reverse and related party exchanges
  • Tax issues for those who purchase debt at a discount

Special Feature
Our transactional approach will feature case studies and other illustrative methods to provide in-depth analysis of many typical but challenging commercial real estate transactions, including, contributions of properties to partnerships, LLCs and REITs and UPREITs, roll-ups of portfolios of multiple properties, redemptions and divisions of partnerships with negative capital accounts, pitfalls and opportunities in leasing transactions, like kind exchanges and much, much more

Program Level – Overview 

Intended Audience - Attorneys at law and accounting firms who advise clients on the tax consequences of real estate transactions; in-house tax professionals who help structure transactions; and professionals interested in exploring the cutting-edge and creative tax planning techniques available for structuring, restructuring and unwinding different types of real estate transactions in today’s challenging environment.

Prerequisites –
Familiarity with the U.S. tax rules affecting real estate.

Advanced Preparation – None

Lecture Topics [Total time 09:59:03]

Segments with an asterisk (*) are available only with the purchase of the entire program.

  • Opening Remarks* [00:03:42]
    Sanford C. Presant, Blake D. Rubin
  • Key Provisions of the 2017 Tax Act Affecting Commercial Real Estate [03:09:55]
    Lary S. Wolf, Andrea Macintosh Whiteway, Robert D. Schachat, Sanford C. Presant, Blake D. Rubin
  • Sophisticated Partnership Structures and Issues – Moving Property to and from Partnerships and REITs [01:44:43]
    Sanford C. Presant, Blake D. Rubin, Lary S. Wolf, Andrea Macintosh Whiteway, Robert D. Schachat
  • Real Estate Investment Trusts – What’s New in the REIT World & Non-U.S. Investors and FATCA [01:14:56]
    Michael Hirschfeld, Emma Preston, Dianne O. Umberger, Sanford C. Presant, Lary S. Wolf
  • Transactions Involving Real Estate – Practical Solutions to Everyday Problems [02:29:59]
    Jill E. Darrow, Sanford C. Presant, Blake D. Rubin, Robert D. Schachat
  • Workouts and Debt Restructuring [01:15:48]
    James B. Sowell, Linda Z. Swartz, Robert D. Schachat

The purchase price of this Web Program includes the following articles from the Course Handbook available online:

  • COMPLETE COURSE HANDBOOK
  • Real Estate Owners: Don’t Get Carried Away by the New Carried Interest Provision (March 15, 2018)
    Andrea M. Whiteway, Maximilian Pakaluk, Blake D. Rubin
  • New Limitation on Active Losses under Tax Cuts and Jobs Act
    Andrea M. Whiteway, Maximilian Pakaluk, Blake D. Rubin
  • Developments in Partnership and Real Estate Taxation in 2016 (September 1, 2016)
    Blake D. Rubin, Andrea M. Whiteway, Gale E. Chan
  • Developments in Partnership and Real Estate Taxation in 2015 (October 1, 2015)
    Gale E. Chan, Blake D. Rubin, Jon G. Finkelstein
  • Developments in Partnership and Real Estate Taxation in 2014 (September 1, 2014)
    Blake D. Rubin, Gale E. Chan, Jon G. Finkelstein
  • Developments in Partnership and Real Estate Taxation in 2013
    Blake D. Rubin, Jon G. Finkelstein, Gale E. Chan
  • Partnership Tax Planning under the New Tax Cuts and Jobs Act Bonus Depreciation Proposed Regulations (October 1, 2018)
    Blake D. Rubin, Andrea M. Whiteway, Maximilian Pakaluk
  • Selected Operating Agreement Tax Allocation Provisions for Limited Liability Companies
    Leslie H. Loffman, Sanford C. Presant
  • Income Recognition Checklist (Problems)
    Leslie H. Loffman, Sanford C. Presant
  • Put a “Bottom” Deficit Restoration Obligation in Your Partnership Liability Allocation Tool Box (September 1, 2014)
    Blake D. Rubin, Andrea Macintosh Whiteway, Jon G. Finkelstein
  • New Temporary and Proposed Partnership Liability Allocation Regulations Are Deeply Flawed and Should Be Withdrawn (February 1, 2017)
    Blake D. Rubin, Andrea Macintosh Whiteway, Maximilian Pakaluk
  • Partnership Liability Allocation Planning, Including the “New” Rules
    Blake D. Rubin, Andrea M. Whiteway, Maximilian Pakaluk
  • Planning for Partnership Liability Allocations, Including the New Proposed Regulations (January 2015)
    Blake D. Rubin, Andrea Macintosh Whiteway, Jon G. Finkelstein
  • Final and Proposed Regulations Regarding Partnership Noncompensatory Options (January 2014)
    Blake D. Rubin, Andrea Macintosh Whiteway, Gale E. Chan, Jon G. Finkelstein
  • Testimony Before the Subcommittee on Select Revenue Measures (May 15, 2013)
    Blake D. Rubin
  • 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)
    Andrea Macintosh Whiteway, Blake D. Rubin
  • New Partnership Disguised Sale Regulations End Leveraged Partnerships (June 1, 2017)
    Andrea Macintosh Whiteway, Maximilian Pakaluk, Blake D. Rubin
  • Partnership Disguised Sales of Property: G-I Holdings Misses the Mark
    Andrea Macintosh Whiteway, Blake D. Rubin, Jon G. Finkelstein
  • Tax Court Goes Overboard in Canal
    Jon G. Finkelstein, Andrea Macintosh Whiteway, Blake D. Rubin
  • Implications of Canal Corporation for Structuring Partnership Transactions
    Blake D. Rubin, Jon G. Finkelstein, Andrea Macintosh Whiteway
  • Is Your Transaction a Partnership Merger or Liquidation and Why You Should Care (January 2015)
    Blake D. Rubin, Andrea Macintosh Whiteway, Jon G. Finkelstein
  • Handling Partnership Mergers and Divisions
    Andrea Macintosh Whiteway, Jon G. Finkelstein, Blake D. Rubin
  • Partnership Equity Extraction Techniques (September 1, 2015)
    Andrea Macintosh Whiteway, Blake D. Rubin, Jon G. Finkelstein
  • UpREIT and DownREIT Transactions: Latest Techniques and Issues (September 1, 2017)
    Andrea M. Whiteway, Blake D. Rubin
  • Opportunities and Pitfalls for the Property Owner in Transactions with a REIT
    Andrea Macintosh Whiteway, Jon G. Finkelstein, Blake D. Rubin
  • Can Code Sec. 704(c) Be Applied to a Capital Gain Dividend Paid by a REIT? (October 1, 2017)
    Maximilian Pakaluk, Andrea M. Whiteway, Blake D. Rubin
  • Defeasing Conduit Loans: Tax Issues, Premiums, Like-Kind Exchanges and “New York Style” (May 2015)
    Blake D. Rubin, Jon G. Finkelstein, Andrea Macintosh Whiteway
  • Capital Gains Planning
    Jill E. Darrow
  • Maximizing Capital Gains in Real Estate Transactions: Case Studies
    Blake D. Rubin
  • Rev. Rul. 2016-15 Holds Real Estate Dealers Cannot Exclude Cancellation of Indebtedness Income, But Is It Correct?
    Andrea Macintosh Whiteway, Blake D. Rubin
  • “Bad Boy” Nonrecourse Carve-Outs in Real Estate Loan Cause It to Be Recourse — or Do They? (May 2016)
    Blake D. Rubin, Andrea Macintosh Whiteway
  • Recourse or Nonrecourse: Treatment of Liabilities for COD and Other Purposes
    Blake D. Rubin, Andrea Macintosh Whiteway, Jon G. Finkelstein
  • Is It Cancellation of Debt (COD) Income?: New IRS Chief Counsel Advice Takes the Gas out of Great Plains Gasification (September 1, 2015)
    Andrea Macintosh Whiteway, Blake D. Rubin, Jon G. Finkelstein
  • Tax Primer for Partnership Workouts
    Leslie H. Loffman, Sanford C. Presant
  • Important Tax Developments Affecting Partnership Workouts
    Leslie H. Loffman, Sanford C. Presant
  • Tax Aspects of Real Estate Workouts
    Leslie H. Loffman, Elliot G. Freier, Sanford C. Presant, Michael G. Frankel, Fred T. Witt
  • Partnership Bankruptcy Tax Issues
    Linda Z. Swartz
  • Final Partnership Debt-for-Equity Regs Deny Creditors’ Losses
    Andrea Macintosh Whiteway, Blake D. Rubin, Jon G. Finkelstein
  • Revenue Ruling 2012-14: The IRS Lends a Helping Hand to Insolvent Partners
    Blake D. Rubin, Andrea Macintosh Whiteway, Jon G. Finkelstein
  • Creative Planning for Partnership Liability Allocations, Including the New Proposed Regulations (PowerPoint slides)
    Blake D. Rubin
  • Selected Tax Allocation Problems for Partnerships and LLCs (PowerPoint slides)
    Leslie H. Loffman, Sanford C. Presant
  • Tax Provision Issues Checklist for LLC and Partnership Agreements (PowerPoint slides)
    Sanford C. Presant
  • Handling UPREIT and DownREIT Transactions: Latest Techniques and Issues (PowerPoint slides)
    Blake D. Rubin
  • Making Section 704(c) Work for You (PowerPoint slides)
    Andrea Macintosh Whiteway, Blake D. Rubin
  • Current Issues in Like-Kind Exchanges (PowerPoint slides)
    Blake D. Rubin
  • Partnerships and Disregarded Entities in Like-Kind Exchanges (PowerPoint slides)
    Blake D. Rubin
  • Maximizing Capital Gains in Real Estate Transactions (PowerPoint slides)
    Blake D. Rubin
  • Hot Like-Kind Exchange Issues (PowerPoint slides)
    Robert D. Schachat
  • Leasing Issues (PowerPoint slides)
    Robert D. Schachat
  • Capital Gains Planning (PowerPoint slides)
    Jill E. Darrow
  • Disposing of Overleveraged Real Estate: Thinking Outside the Box (PowerPoint slides)
    Blake D. Rubin
  • Debt Workouts and Restructurings (PowerPoint slides)
    Robert D. Schachat, James B. Sowell, Linda Z. Swartz

Presentation Material

  • 20% Deduction for Qualifying Business Income IRC Section 199A
    Lary S. Wolf
  • Qualified Opportunity Fund Finance: An Introduction to the Tax Incentive Everyone is Talking About
    Sanford C. Presant, James Lang
  • Selected TCJA Provisions Affecting Real Estate
    Blake D. Rubin, Robert D. Schachat, Andrea Macintosh Whiteway
  • Tax Provision Issues Checklist for LLC and Partnership Agreements
    Sanford C. Presant
  • Rehabilitation Tax Credit
    Lary S. Wolf
  • Tax Cuts and Jobs Act Real Estate Issues
    Robert D. Schachat
  • Extracting Equity on a Tax-Free Basis
    Blake D. Rubin
  • Partnership Liability Allocation Planning, Including the New Regulations
    Andrea Macintosh Whiteway
  • Selected Tax Allocation Problems for Partnerships and LLCs
    Sanford C. Presant
  • Non-U.S. Investors Participating in Your Real Estate Deal
    Michael Hirschfeld, Emma Preston
  • Capital Gains Planning
    Jill E. Darrow
  • Hot Topics in Like-Kind Exchange Issues
    Robert D. Schachat
  • Leasing Issues
    Robert D. Schachat
  • Debt Workouts and Restructurings
    Robert D. Schachat, James B. Sowell, Linda Z. Swartz
Co-Chair(s)
Sanford C. Presant ~ Greenberg Traurig, LLP
Speaker(s)
Jill E. Darrow ~ Katten Muchin Rosenman LLP
Michael Hirschfeld ~ AndersenTax
Emma Preston ~ KPMG LLP
James B. Sowell ~ KPMG LLP
Linda Z. Swartz ~ Cadwalader, Wickersham & Taft LLP
Lary S. Wolf ~ Roberts & Holland LLP
General credit information about this format appears below. For credit information specific to this program, please choose your jurisdiction(s) in the Credit Information box on the right-hand side of this page.

PLI’s live and on-demand webcasts are single-user license products intended for an individual registrant only. Credit will be issued only to the individual registered.


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Connecticut: Effective January 1, 2017, all PLI products can fulfill Connecticut’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Delaware:  PLI’s on-demand web programs qualify as “eCLE” credit. Attorneys are limited to 12 credits of eCLE per reporting period, no more than 6 of which may be audio-only.

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New Jersey:  PLI’s on-demand web programs qualify as “alternative verifiable learning formats” credit. Attorneys are limited to 12 credits of alternative verifiable learning formats per reporting period.

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New York

Experienced Attorneys:  All PLI products can fulfill New York’s CLE requirements for experienced attorneys. There is no limit to the number of credits an attorney can earn via PLI products.

Newly Admitted Attorneys:  PLI’s transitional on-demand web programs can be used to fulfill the requirements for New York newly admitted attorneys. Only professional practice and law practice management credits may be earned via transitional on-demand web programs. Ethics and skills credits may not be earned via on-demand web programs.

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Pennsylvania:  PLI’s on-demand web programs qualify as “distance learning” credit. Attorneys are limited to 6 credits of distance learning per reporting period.

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Rhode Island:  PLI’s on-demand web programs qualify as “video replay” credit. Attorneys are limited to 6 video replay credits per reporting period.

South Carolina:  PLI’s on-demand web programs qualify as “alternatively delivered” credit. Attorneys are limited to 6 credits of alternatively delivered programs per reporting period.

Tennessee:  PLI’s on-demand web programs qualify as “distance learning” credit. Attorneys are limited to 8 credits of distance learning per reporting period.

Texas:  All PLI products can fulfill Texas’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Utah:  PLI’s on-demand web programs qualify as “self-study” credit. Attorneys are limited to 12 credits of self-study per reporting period.

Vermont:  PLI’s on-demand web programs qualify as “self-study” credit. Attorneys are limited to 10 credits of self-study per reporting period.

Virgin Islands:  All PLI products can fulfill the Virgin Islands’ CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Virginia:  PLI’s on-demand web programs qualify as “pre-recorded” credit. Attorneys are limited to 8 credits of pre-recorded programs per reporting period.

Washington:  All PLI products can fulfill Washington’s CLE requirements. There is no limit to the number of credits an attorney can earn via PLI products.

West Virginia:  PLI’s on-demand web programs qualify as “online” credit. Attorneys are limited to 12 credits of online instruction per reporting period.

Wisconsin:  PLI’s on-demand web programs qualify as “repeated, on-demand” credit. Attorneys are limited to 15 credits of repeated, on-demand programs per reporting period. No ethics credits can be earned via on-demand web programs.

Wyoming:  PLI’s on-demand web programs qualify as “self-study” credit. Attorneys are limited to 6 credits of self-study per reporting period.


CPD Jurisdictions

British Columbia (CPD-BC):  PLI’s on-demand web programs are not eligible for CPD-BC credit unless viewed with at least one other attorney or an articled student. In this case, the credit must be recorded as a “study group.”

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Quebec (CPD-QC):  PLI’s on-demand web programs can fulfill Quebec’s CPD requirements.

Hong Kong (CPD-HK):  PLI’s on-demand web programs are not approved for CPD-HK credit.

United Kingdom (CPD-UK):  PLI’s on-demand web programs can fulfill the United Kingdom’s CPD requirements.

Australia (CPD-AUS):  PLI’s on-demand web programs may fulfill Australia’s CPD requirements. Credit limits for on-demand web programs vary according to jurisdiction. Please refer to your jurisdiction’s CPD information page for specifics.

Alberta (CPD-ALBERTA):  All PLI products can fulfill Alberta’s CPD requirements. There is no limit to the number of credits an attorney can earn via PLI products.

Dubai (CLPD-DUBAI):  PLI’s on-demand web programs may fulfill CLPD credit requirements.


Other Credit Types

CPE Credit (NASBA):  Select on-demand web programs qualify as the “QAS Self-Study” delivery method. Please check the Credit Information box on the right-hand side of this page to verify CPE credit availability.

IRS Continuing Education (IRS-CE):  PLI’s on-demand web programs may fulfill IRS-CE requirements. To request IRS-CE credit, please notify PLI at plicredits@pli.edu of your request and include your Preparer Tax Identification Number (PTIN).

Certified Fraud Examiner CPE:  PLI’s on-demand web programs may fulfill Certified Fraud Examiner CPE requirements. To request CPE credit or find out which programs offer CPE, please contact PLI at plicredits@pli.edu.

IAPP Continuing Privacy Credit (CPE):  PLI’s on-demand web programs may fulfill Privacy CPE credit requirements.

HR Recertification (HRCI):  PLI’s on-demand web programs may fulfill HR credit requirements.

SHRM Recertification (SHRM):  PLI’s on-demand web programs qualify as "self-paced" credit. SHRM professionals are limited to 30 credits of self-paced programs per recertification period.

Compliance Certification Board (CCB):  PLI’s on-demand web programs qualify as “self-study” credit. Candidates are limited to 10 self-study credits per 12-month period, and certification holders are limited to 20 self-study credits per 2-year renewal period.

Certified Anti-Money Laundering Specialists Certification (CAMS):  PLI’s on-demand web programs are not approved for CAMS credit.

New York State Social Worker Continuing Education (SW CPE):  PLI’s on-demand web programs are not approved for SW CPE credit.

American Bankers Association Professional Certification (ABA):  PLI’s on-demand web programs may fulfill ABA credit requirements.

Certified Financial Planners (CFP):  PLI’s on-demand web programs are not approved for CFP credit.

 

Related Items

Handbook  Course Handbook Archive

21st Annual Real Estate Tax Forum Sanford C. Presant, Greenberg Traurig, LLP
Blake D. Rubin, EY
 
20th Annual Real Estate Tax Forum Leslie H. Loffman, Proskauer
Sanford C. Presant, Greenberg Traurig, LLP
Blake D. Rubin, EY
 
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