FacultyFaculty/Author Profile
Andrea Macintosh Whiteway

Andrea Macintosh Whiteway

EY

Washington, DC, USA


Andrea Macintosh Whiteway is a principal in the National Tax Department of Ernst & Young LLP, based in Washington, D.C.  She has substantial experience in sophisticated tax planning involving the use of partnerships, including in the dispositions and acquisitions of real estate and operating businesses, complex partnership transactions, real estate investment trust (REIT) tax status and tax structured dispositions of real estate involving REITs, corporate acquisitions and mergers, corporations and structuring private REITs. Andrea advises on forward and reverse like-kind exchanges and exchanges of tenancy in common interests in real estate.

Andrea has been listed in the 2008 to 2017 editions of The Best Lawyers in America in the area of tax law and has also been selected as a fellow of the American College of Tax Counsel. She is ranked by The Legal 500 United States and Chambers USA as a leader in her field. Washingtonian Magazine named her as one of the top lawyers in Washington, D.C. Andrea is also recognized in Washington D.C. Super Lawyers. She is AV rated by Martindale-Hubbell and has the highest rating by AVVO.

Andrea had the honor of being the first woman to serve as chair of the Real Estate Committee of the American Bar Association Section of Taxation and currently serves on the Section of Taxation Nominating Committee. She also serves as Chair of the Federal Taxation of Real Estate Committee of the American Bar Association Section of Real Property, Trusts and Estates. She serves on the Advisory Board of the NYU Institute on Federal Taxation. She is also a former member of the steering committee of the District of Columbia Bar Section of Taxation and a past Chair of its Pass-throughs and Real Estate Committee. Andrea is an active member of Urban Land Institute.  She also serves on the Tax Policy Advisory Committee of the Real Estate Roundtable and is a member of the National Association of Real Estate Investment Trusts.

Andrea is the author of over 100 professional articles and has delivered more than 100 lectures on tax topics at conferences across the United States, including at the Tax Executives Institute, NYU Federal Tax Institute, Texas Federal Tax Institute, Tulane Tax Institute, ABA Tax Section Meetings, AICPA Conferences, ALI-ABA and Practising Law Institute seminars, University of Texas School of Law Tax Conference, Federal Bar Association and District of Columbia Bar Association programs. Andrea was recognized as one of Maryland’s Top 100 Women for 2007 by The Daily Record which presents this award to "high-achieving Maryland women who are making an impact through their leadership, community service and mentoring." 

Andrea Macintosh Whiteway is associated with the following items:
CHB Chapters  CHB Chapters Corporate Tax Strategies and Techniques Using Partnerships, LLCs and Other Strategic Alliances 2016 (PowerPoint slides) - Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2016, Tuesday, October 18, 2016
Cancellation of Indebtedness Income Deferral in Economic Stimulus Bill Raises Complex Issues for Partnerships - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Rev. Proc. 2009-37 Allows Flexibility for Partnerships Electing New C.O.D. Income Deferral - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Jobs Act Tightens Partnership Tax Rules - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Opportunities and Pitfalls for the Property Owner in Transactions with a REIT - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Disguised Sales of Partnership Interests: An Analysis of the Proposed Regulations - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Recourse or Nonrecourse: Liability Treatment for COD and Other Purposes - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
A Section 754 Paradox: Basis Step-Up Triggers Gain Recognition in UPREIT and Other Partnership Contribution Transactions - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Tax Court Sticks to Its Guns and Sticks It to Taxpayers in Hubert Case - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Tax Court Respects Partnership’s Property Distribution: Countryside Limited Partnership v. Commissioner - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Making Section 704(c) Work for You (PowerPoint slides) - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Is It Cancellation of Debt (COD) Income?: New IRS Chief Counsel Advice Takes the Gas out of Great Plains Gasification (September 1, 2015) - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Proposed Regulations on Allocating Partnership Liabilities to Owners of Disregarded Entities - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Rev. Rul. 99-43: When to Hold’em, When to Fold’em, and When to Book-Down - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
New Regulations Regarding Assumption of Partnership Liabilities - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Recent Developments in Partnership and Real Estate Taxation in 2015 (September 1, 2016) - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
New Ruling on Like-Kind Exchanges of Leveraged Property Solves Problems and Creates Opportunities - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Proposed Regulations on Partnership Interests Issued for Services Create Problems and Opportunities - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
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 - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Put a “Bottom” Deficit Restoration Obligation in Your Partnership Liability Allocation Tool Box (September 1, 2014) - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Exploring the Outer Limits of Section 704(c)(1)(A) - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Planning for Partnership Liability Allocations, Including the New Proposed Regulations (January 2015) - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Tax Court Goes Overboard in Canal - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Defeasing Conduit Loans: Tax Issues, Premiums, Like-Kind Exchanges and “New York Style” (May 2015) - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Is Your Transaction a Partnership Merger or Liquidation and Why You Should Care (January 2015) - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Proposed Regulations on Application of the Anti-Mixing Bowl Rules After a Partnership Merger to Apply Prospectively - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Partnership Equity Extraction Techniques (September 1, 2015) - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
"Bad Boy" Nonrecourse Carve-Outs in Real Estate Loan Cause It to Be Recourse—or Do They? (May 2016) - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Protecting OP Unitholders in REIT Going Private Transactions - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Revenue Ruling 2012-14: The IRS Lends a Helping Hand to Insolvent Partners - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Recent Developments Regarding Disguised Sales of Partnership Interests - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Sixth Circuit Vacates Controversial Hubert Case Dealing with Partner’s At-Risk Amount - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Final Regulations on the Treatment of Disregarded Entities for Purposes of Characterizing and Allocating Liabilities Under Code Sec. 752: Questions and Complexities Continue - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Tax Planning for the Sale or Other Disposition of Overencumbered Real Estate - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Final Partnership Liability Regulations Target “Son of Boss” Abuse But Sweep More Broadly - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
New Ruling on Allocating Partnership Liabilities Disregards Technicalities to Absolve Taxpayer of Gain - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Partnership Disguised Sales of Property: G-I Holdings Misses the Mark - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Final and Proposed Regulations Regarding Partnership Noncompensatory Options (January 2014) - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Partnership Mergers, the Anti-Mixing Bowl Rules and Rev. Rul. 2004-43: How Could the Service Be So Wrong? - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Rev. Rul. 2016-15 Holds Real Estate Dealers Cannot Exclude Cancellation of Indebtedness Income, But Is It Correct? - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Final Partnership Debt-for-Equity Regs Deny Creditors’ Losses - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Implications of Canal Corporation for Structuring Partnership Transactions - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Creditors Beware: Proposed Partnership Debt-for-Equity Regulations Deny Your Tax Loss - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
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) - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
New Proposed Regulations on Mergers Involving Disregarded Entities - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Handling Partnership Mergers and Divisions - Real Estate Tax Forum (19th Annual), Tuesday, February 07, 2017
Implications of Section 704(c) for Negotiating a Partnership Agreement (Chicago)(PowerPoint slides) - Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2017, Friday, June 09, 2017
Making Section 704(c) Sing for You - Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2017, Friday, June 09, 2017
Corporate Tax Strategies and Techniques Using Partnerships, LLCs and Other Strategic Alliances 2017 (PowerPoint slides) - Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2017, Wednesday, October 18, 2017
Web Segment  Web Segment Sophisticated Partnership Structures and Issues – Moving Property to and from Partnerships and REITs - 19th Annual Real Estate Tax Forum, Friday, February 03, 2017
MP3 Audio  MP3 Audio Sophisticated Partnership Structures and Issues – Moving Property to and from Partnerships and REITs - Sophisticated Partnership Structures and Issues – Moving Property to and from Partnerships and REITs, Friday, February 03, 2017
Transcripts  Transcripts Sophisticated Partnership Structures and Issues – Moving Property to and from Partnerships and REITs - Sophisticated Partnership Structures and Issues – Moving Property to and from Partnerships and REITs, Friday, February 03, 2017
MP4 - Mobile Video Seg  MP4 - Mobile Video Seg Sophisticated Partnership Structures and Issues – Moving Property to and from Partnerships and REITs - Sophisticated Partnership Structures and Issues – Moving Property to and from Partnerships and REITs, Friday, February 03, 2017
Treatise Chapters  Treatise Chapters Cancellation of Indebtedness Income Deferral in Economic Stimulus Bill Raises Complex Issues for Partnerships - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Revenue Ruling 2012–14: The IRS Lends a Helping Hand to Insolvent Partners - The Corporate Tax Practice Series, Wednesday, February 08, 2017
New Legislation Tightens Partnership Tax Rules - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Creditors Beware: Proposed Partnership Debt-for-Equity Regulations Deny Your Tax Loss - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Final Partnership Debt-for-Equity Regs Deny Creditors’ Losses - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Tax Court Goes Overboard in Canal - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Final Regulations on the Treatment of Disregarded Entities for Purposes of Characterizing and Allocating Liabilities Under Code Sec. 752: Questions and Complexities Continue - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Sixth Circuit Vacates Controversial Hubert Case Dealing with Partner’s At-Risk Amount - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Tax Court Respects Partnership’s Property Distribution: Countryside Limited Partnership v. Commissioner - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Proposed Regulations on Partnership Equity for Services Create Problems and Opportunities - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Partnership Disguised Sales of Property: G-I Holdings Misses the Mark - The Corporate Tax Practice Series, Wednesday, February 08, 2017
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 - The Corporate Tax Practice Series, Wednesday, February 08, 2017
New Proposed Regulations on Disguised Sales of Partnership Interests - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Creative Transactional Planning Using the Partnership Merger and Division Regulations - The Corporate Tax Practice Series, Wednesday, February 08, 2017
A 'Guaranteed' Debacle: Proposed Partnership Liability Regulations - The Corporate Tax Practice Series, Wednesday, February 08, 2017
Proposed Regulations on Application of the Anti-Mixing Bowl Rules After a Partnership Merger to Apply Prospectively - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Creative Transactional Planning Using the Partnership Merger and Division Regulations - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Proposed Regulations on Partnership Interests Issued for Services: Practical Problems and Opportunities - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Recent Developments in Partnership and Real Estate Taxation - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Implications of Canal Corporation for Structuring Partnership Transactions - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Partnership Mergers, the Anti-Mixing Bowl Rules and Rev. Rul. 2004-43: How Could the Service Be So Wrong? - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Making Section 704(c) Sing for You - The Partnership Tax Practice Series, Tuesday, August 01, 2017
The Impact of Disregarded Entities on Partnership Liability Allocations: Proposed Regulations Under I.R.C. Section 752 - The Partnership Tax Practice Series, Tuesday, August 01, 2017
New COD Income Deferral Guidance Allows Flexibility for Partnership - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Planning for Partnership Liability Allocations Including the New Proposed Regulations - The Partnership Tax Practice Series, Tuesday, August 01, 2017
New Proposed Regulations on Mergers Involving Disregarded Entities - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Guarantees, DROs, and CCOs: Getting Partnership Liability Allocations Right - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Here Comes the Kitchen Sink: IRS Throws “Everything But” at Two Partnership Tax Deferral Structures - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Opportunities and Pitfalls for the Property Owner in Transactions with a REIT - The Partnership Tax Practice Series, Tuesday, August 01, 2017
IRS Helps Insolvent Partners in Revenue Ruling 2012-14 - The Partnership Tax Practice Series, Tuesday, August 01, 2017
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 - The Partnership Tax Practice Series, Tuesday, August 01, 2017
New Taxpayer Favorable PLRs Allow Gain on Sale of Partnership Assets to Be Offset by Disallowed Loss on Earlier Sale of Partnership Interest - The Partnership Tax Practice Series, Tuesday, August 01, 2017
New Ruling on Allocating Partnership Liabilities Disregards Technicalities to Absolve Taxpayer of Gain - The Partnership Tax Practice Series, Tuesday, August 01, 2017
New Proposed Regulations on Disguised Sales of Partnership Interests - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Final and Proposed Regulations Regarding Partnership Noncompensatory Options - The Partnership Tax Practice Series, Tuesday, August 01, 2017
"Bad Boy" Nonrecourse Carve-Outs in Real Estate Loan Cause It to Be Recourse—or Do They? - The Partnership Tax Practice Series, Tuesday, August 01, 2017
A Section 754 Paradox: Basis Step-Up Triggers Gain Recognition in UPREIT and Other Partnership Contribution Transactions - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Final Regulations on the Treatment of Disregarded Entities for Purposes of Characterizing and Allocating Liabilities Under Code Sec. 752: Questions and Complexities Continue - The Partnership Tax Practice Series, Tuesday, August 01, 2017
A ‘Guaranteed’ Debacle: Proposed Partnership Liability Regulations - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Sixth Circuit Vacates Controversial Hubert Case Dealing with Partner’s At-Risk Amount - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Rev. Rul. 99-43: When to Hold’em, When to Fold’em, and When to Book-Down - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Exploring the Outer Limits of Section 704(c)(1)(A) - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Tax Court Goes Overboard in Canal - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Is It Cancellation of Debt (COD) Income?: New IRS Chief Counsel Advice Takes the Gas Out of Great Plains Gasification - The Partnership Tax Practice Series, Tuesday, August 01, 2017
JOBS Act Tightens Partnership Tax Rules - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Creditors Beware: Proposed Partnership Debt-for-Equity Regulations Deny Your Tax Loss - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Take the Money and Run: Extracting Equity on a Tax-Free Basis - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Tax Court Respects Partnership’s Property Distribution: Countryside Limited Partnership v. Commissioner - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Put a “Bottom” Deficit Restoration Obligation in Your Partnership Liability Allocation Tool Box - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Tax Court Sticks to Its Guns and Sticks It to Taxpayers in Hubert Case - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Partnership Disguised Sales of Property: G-I Holdings Misses the Mark - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Recourse or Nonrecourse: Liability Treatment for COD, Other Purposes - The Partnership Tax Practice Series, Tuesday, August 01, 2017
New Partnership Liability Regulations Target Abuse but Sweep More Broadly - The Partnership Tax Practice Series, Tuesday, August 01, 2017
Recent Developments Regarding Disguised Sales of Partnership Interests - The Partnership Tax Practice Series, Tuesday, August 01, 2017
On-Demand Web Programs  On-Demand Web Programs 19th Annual Real Estate Tax Forum, Wednesday, February 15, 2017, New York, NY
Live Seminar  Live Seminar Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2017, Wednesday, December 06, 2017, Los Angeles, CA
20th Annual Real Estate Tax Forum, Monday, January 29, 2018, New York, NY
Live Webcast  Live Webcast 20th Annual Real Estate Tax Forum, Monday, January 29, 2018, New York, NY
PLI Grpcast-Live Web  PLI Grpcast-Live Web 20th Annual Real Estate Tax Forum, Monday, January 29, 2018, New Brunswick , NJ
20th Annual Real Estate Tax Forum, Monday, January 29, 2018, Atlanta, GA
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