See Credit Details Below
Overview
Why You Should Attend
This year’s program will continue to focus on transactions, highlighting the tax problems encountered, and structuring adopted by, practitioners in today’s typical commercial real estate transactions. We will explore the unique challenges created by the current market, and the impact of recent tax legislation, including any proposed legislation and extenders following the 2024 Presidential election, and the Inflation Reduction Act (“IRA”), and examine the range of approaches and solutions being used by the experts following the passage of this new legislation, the 2017 Tax Act (formerly the Tax Cuts and Jobs Act – “TCJA”), the Coronavirus Aid, Relief, and Economic Security Act (the “CARES” Act), and subsequent guidance thereunder.
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. 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.
What You Will Learn
After completing this program, participants will be able to:
- Select the right Section 704(c) method for your contributed property
- Draft partnership agreements to deal with the recent partnership audit and “partnership representative” rules
- Structure your real estate transactions to avoid income recognition traps and minimize taxes under Sections 704(b), 704(c), 707, 737 and 752
- Contribute real estate to real estate investment trusts (REITs) in a tax efficient manner
- Execute challenging commercial real estate transactions, including, contributions of properties to partnerships, LLCs and REITs and UPREITs, roll-ups of portfolios of multiple properties, Qualified Opportunity Funds (“QOFs” and “QOZBs”), redemptions and divisions of partnerships with negative capital accounts
Who Should Attend
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.
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
Industries
Register Now
Register Now
Privileged Members attend this program at no cost.
Email info@pli.edu to request live captioning up to 48 hours before the program takes place.
Course materials will be available to attendees prior to the start of the program
Credit Details
Credit Details For All Jurisdictions For This Program
Jurisdiction | Status | Total | Credit Details |
---|
- Feb 3, 2025
9:00 AM EST
Opening Remarks
9:15 AM EST
Key Provisions of the Inflation Reduction Act (“IRA”); TCJA and CARES Act Affecting Commercial Real Estate
- Appreciate the new opportunities for real estate owners to take advantage of, and monetize, tax credits
- Apply the real estate exception to business interest deductibility
- Identify the CARES Act changes to cost recovery and expensing of qualified improvement property
- Describe the latest developments in qualified opportunity zones and carried interests
10:30 AM EST
10:45 AM EST
Sophisticated Partnership Structures and Issues – Moving Property to and from Partnerships and REITs
- Select the right Section 704(c) method for contributed property
- Use non-traded REITs in common structures
- Transfer property to partnerships (joint venture and UPREIT contributions and roll-ups) without current tax
- Employ strategies for avoiding dealer status by identifying prohibited transactions
12:00 PM EST
1:15 PM EST
Real Estate Investment Trusts – What’s New in the REIT World
- Advise clients on the specific challenges REITs might face when debt markets are tight
- Conduct transactions with REITs in a tax efficient manner, identifying issues and traps
- Be prepared to satisfy the REIT distribution requirements in a variety of transactions
- Take advantages of green energy incentives
2:15 PM EST
Tax Planning for Non-U.S. Real Estate Investors
- Manage the issues raised by having non-U.S. investors as joint venture partners
- Comply with relevant withholding requirements
- Employ REITs and blocker entities
- Evaluate the merits of debt vs. equity structures
3:15 PM EST
3:30 PM EST
Workouts and Debt Restructuring in the Real Estate Context
- Work with lenders on forbearance and other debt modifications
- Differentiate between cancellation of debt (“COD”) and Section 1001 exchange gain
- Identify situations where it is possible to acquire debt at a discount without tax
- Manage the challenges of dealing with underwater properties
4:30 PM EST
Transactions Involving Real Estate – Practical Solutions to Everyday Problems
- Structure like-kind exchanges involving partnerships where some partners want cash instead of property
- Execute reverse and related party exchanges, parking transactions and build-to-suit exchanges
- Conduct leasing transactions
- Manage the tax consequences of lease terminations
- Convert ordinary income into capital gains
- Defer gain recognition
- Take small structuring steps that can have a major impact on your client’s transactions