"J0-003R."--Spine Prepared for distribution at the program of the same name held February-March 2001.
Contents:
Preserving capital gains in real estate transactions -- Real estate tax planning -- REITS modernized -- Tax planning for the property owner in REIT acquisitions -- Doing a deal with a REIT -- Ups and downs of DownREITs -- Tax treatment of REITs and REIT shareholders -- REIT mergers & acquisitions: tax consequences -- Income recognition checklist for property contributions to UPREITS and other partnerships -- Effecting tax-free property contributions to UPREITs and other partnerships -- Avoid taxes for property contributions -- A Section 754 paradox -- Tax accounting issues in mergers and acquisitions -- History of Section 704(b) -- Rev. rul. 99-43: when to hold'em, when to fold'em, and when to book-down -- Exploring the outer limits of Section 704(c)(1)(A) -- Section 704 (c)(1)(A) regulations -- Section 704 (C)(1)(B) final regulations -- Section 737 regulations -- Allocation of nonrecourse liabilities -- Allocating partnership liabilities under Section 752 of the Internal Revenue Code -- Impact of excluded COD income on S Shareholders -- New decision casts a shadow on the contested liability exception to COD income -- Briarpark and the unexpected limits to careful tax planning -- Unsecured borrowing treated as qualified nonrecourse financing under Code Secs. 752 and 465 -- IRS issues taxpayer-friendly qualified nonrecourse financing regs -- Taxation of real estate investment trust -- Inquiry into certain income tax aspects of investment partnerships -- Tax aspects of partnership dilution provisions -- Dissecting the Section 707(a)(2)(B) regulations on partnership disguised sales -- Liabilities under the disguised sale rules of Section 707 -- Sales partnership interests -- Recent developments regarding disguised sales of partnership interests -- IRS attempts to "demonize" the partnership: the final Section 701 regulations; antiabuse regulations or simply abusive regulations? -- Tax aspects of real estate investment trusts -- Planning for taxable acquisitions involving real estate investment trusts -- Dealer sales rules for real estate investment trusts -- Tax consequences of real estate; workouts and bankruptcies -- Tax aspects of real estate workouts -- Nonrecourse debt and securitized financing -- Peracchi and making something out of nothing, or does debt have a zero basis to its maker and further ruminations on the substance and form of transactions -- Creative strategies for the disposition of overleveraged real estate -- Final Section 467 regulations present problems and opportunities -- Tax treatment of environmental remediation costs -- Tax treatment of environmental cleanup costs -- Maximizing capital gains in real estate transactions -- Disposition of real estate; Capital Gains vs. Ordinary Income -- Preserving capital gains in real estate transactions --
Series:
Tax law and estate planning series Tax law and practice course handbook series. no. J-488-J-490
This resource is supported by the Institute of Museum and Library Services under the provisions of the Library Services and Technology Act as administered by State Library of Iowa.