Original program date 10/13/2021
Tax issues in major real estate transactions – property development, long-term ownership, build-and-sell, like-kind exchanges – often drive the structures of these deals. If not properly considered, tax issues can also have a major adverse impact on the underlying economics of a deal. The structure of a transaction can impact the timing and amount of gain, the treatment of losses (often very valuable to participants), and even the tax rate. At every stage of a transaction, tax plays an important role. This program will provide you with a practical guide to major tax planning issues in real estate deals, including choice of entity, capital gains and distribution planning, and advanced like-kind exchange issues.
• Choice of entity considerations – contributions, distributions, and eventual sales
• Acquiring property in a form to minimize taxes later
• Understanding allocation and distribution provisions – layered allocations, target/forced allocations, built-in-gain (or loss) allocations
• Understanding and drafting for continuing ownership, including capital shifts and other shifts in ownership
• Deductions arising from non-recourse debt and minimum gain chargebacks
• Advanced Like-Kind techniques for deferring gain on the disposition of property
• Techniques for using partnerships – mixing bowl partnerships, freeze partnerships, leveraged acquisition partnerships
• Installment sales and cross-purchase/redemption agreements
• Capital gain tax planning and the 3.8% tax on net investment income
Note: This material qualifies for self-study credit only. Pursuant to Regulation 15.04.5, a lawyer may receive up to six hours of self-study credit in a reporting year. Self-study programs do not qualify for GAL Certification, ethics, elimination of bias or Kansas credit.
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