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