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Creative Tax Planning for Real Estate Transactions
This ALI CLE Program originally took place on November 2, 2011 and ended on November 4, 2011.

The following products were produced as a result of this program: Coursebook

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Coursebook

Table of Contents (12 pp)

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Fundamentals of Partnership Taxation (20 pp)

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Hot Topics in Partnership and Real Estate Taxation (36 pp)

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Condominium Developers Can Avoid the Long-Term Contract Rules While Waiting for Code Section 460 Regulations (8 pp)

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IRS Stretches to Help a Taxpayer in New Disguised Sale Private Letter Ruling (10 pp)

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Partnership Disguised Sales of Property: G-I Holdings Misses the Mark (22 pp)

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Tax Court Sticks to Its Guns and Sticks It to Taxpayers in Hubert Case (22 pp)

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Proposed Regulations on Application of the Anti-Mixing Bowl Rules After a Partnership Merger to Apply Prospectively (26 pp)

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Tax Court Respects Partnership’s Property Distribution: Countryside Limited Partnership v. Commissioner (30 pp)

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Partnership Agreement Drafting Session: How to Structure and Document Joint Ventures (28 pp)

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Worthless Partnership Interests (30 pp)

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Economic Substance Doctrine (18 pp)

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Tax Court Goes Overboard in Canal (14 pp)

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Structuring Considerations in Light of Canal Corporation (14 pp)

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Section 704(c) Allocations (38 pp)

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Rev. Rul. 99-43: When to Hold’em, When to Fold’em, and When to Book-Down (18 pp)

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A Section 754 Paradox: Basis Step-Up Triggers Gain Recognition in UPREIT and Other Partnership Contribution Transactions (12 pp)

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The Proposed Regulations on Partnership Allocations with Respect to Contributed Property (22 pp)

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Rev. Proc. 2009-37 Provides Flexibility for Partnership Debtors Deferring COD Income (14 pp)

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Cancellation of Indebtedness Income Deferral in Economic Stimulus Bill Raises Complex Issues for Partnerships (28 pp)

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Creditors Beware: Proposed Partnership Debt-for-Equity Regulations Deny Your Tax Loss (24 pp)

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Planning for the Disposition of Real Estate Encumbered by Debt in Excess of Value (36 pp)

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Recourse or Nonrecourse: Treatment of Liabilities in a Complex World (28 pp)

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Distinguishing Recourse from Nonrecourse Liabilities (and Why It Matters) (16 pp)

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Tax Traps Frequently Encountered with Leases – Terminations, Tenant Improvement Allowances, Free Rent – from Both Landlord and Tenant Perspectives (32 pp)

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Tax Issues in Defeasing a Conduit Loan, Including in a Like-Kind Exchange (16 pp)

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Rev. Rule 2003-56 Provides New Guidelines on Like-Kind Exchanges of Leveraged Property (10 pp)

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Partnerships and Disregarded Entities in Like-Kind Exchanges (18 pp)

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Creative Planning to Control Partnership Liability Allocations (24 pp)

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Final Partnership Liability Regulations Target “Son of Boss” Abuse but Sweep More Broadly (30 pp)

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New Ruling on Allocating Partnership Liabilities Disregards Technicalities to Absolve Taxpayer of Gain (20 pp)

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Here Comes the Kitchen Sink: IRS Throws “Everything but” at Two Partnership Tax Deferral Structures (14 pp)

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Drafting Tax Distribution Clauses (4 pp)

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Selected Operating Agreement Tax Allocation Provisions for Limited Liability Companies (12 pp)

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Tax Aspects of the Initial Partnership or LLC Negotiation (12 pp)

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Joint Ventures with Tax-Exempt Entities and Taxable Operators (including REITs) (12 pp)

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Selected Tax Allocation Problems for Partnerships and LLCs (14 pp)

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Making Section 704(c) Work for You (28 pp)

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Recent Developments Affecting Real Estate and Pass Through Entities (70 pp)

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Making Section 704(c) Work for You (52 pp)

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Hot Like-Kind Exchange Issues (56 pp)

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Working with the Partnership Liability Allocation Rules: Guarantees, DROs and More (64 pp)

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Recent Developments in Partnership and Real Estate Taxation (188 pp)

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Estate Planning for Real Estate Owners in Changing Times (102 pp)

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Take the Money and Run: Extracting Equity on a Tax-Free Basis (168 pp)

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Tax Issues in Real Estate Workouts (262 pp)

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