23rd Annual Real Estate Tax Forum 2021 | Practising Law Institute (PLI) | 8 February 2021 | TBA, New York, NY - Live

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, including the impact of the Covid-19 pandemic, and examine the range of approaches and solutions being used by the experts following the passage of 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?

• The latest developments in real estate taxation and partnership taxation (legislative, administrative and judicial), including:
Impact of the TCJA and administrative guidance on real estate
- Impact of the CARES Act changes to the TCJA and associated relief provisions
- Analysis of current structures in light of the final Qualified Opportunity Zone Fund (“QOF”) regulations, and any additional guidance
- 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 and “partnership representative” rules
- Changes to the partnership disguised sale regulations that affect “leveraged partnerships” but also many other common transactions
• Structuring to maximize capital gain and avoid “dealer” status; 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; and debt modification and cancellation of debt (“COD”) issues arising following the Covid-19 pandemic

2021 Speakers

CHAIRPERSONS:

Sanford C. Presant
Greenberg Traurig, LLP

Andrea Macintosh Whiteway
EY

SPEAKERS:

Cristina Arumi
Hogan Lovells (US) LLP

Jill E. Darrow
Katten

Adam S. Feuerstein
PwC

David L. Friedline
Deloitte Tax LLP

Michael Hirschfeld
Andersen Tax LLC

Robert D. Schachat

Bahar A. Schippel
Snell & Wilmer L.L.P.

James B. Sowell
KPMG LLP

Linda Z. Swartz
Cadwalader, Wickersham & Taft LLP

Dianne O. Umberger