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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Wednesday, October 16, 2024

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00
CLE
CPE
ALL

This CLE/CPE webinar will provide tax counsel and advisers an in-depth analysis of key tax planning techniques and challenges for real estate investors. The panel will discuss strategies for key tax planning considerations for the acquisition, ownership and ultimate disposition of real estate.

Faculty

Patrick J. McCormick
Partner
Rimon, P.C.

Mr. McCormick specializes in the areas of international taxation and multinational trusts and estates. He has published assorted national articles and given innumerous national and local presentations on assorted areas of international tax. He is licensed to practice in the State of New Jersey and the Commonwealth of Pennsylvania.

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Jeffrey M. Rosenfeld
Partner
Blank Rome LLP

Mr. Rosenfeld concentrates his practice in the area of business tax law. He counsels clients in a broad array of tax matters including domestic and international tax matters, state and local tax planning, tax-efficient structuring of domestic and international mergers, acquisitions, divestitures, reorganizations, spin-offs, redemptions and liquidations, formation, operation and acquisition of Subchapter S Corporations, partnerships and limited liability companies. He counsels clients regarding undeclared foreign bank accounts, including “FBAR” reporting obligations.

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Michael I. Sanders
Partner
Blank Rome LLP

Mr. Sanders focuses his practice in the area of taxation, particularly in matters affecting partnerships, limited liability companies, S-corporations, real estate, tax controversy, and estate planning, including trusts and estates. He also has a large practice in the area of exempt organizations involving healthcare and low-income housing, associations and joint ventures between for-profits and nonprofits, as well as structuring New Markets Tax Credit ("NMTC") and Historic Tax Credit ("HTC") transactions. He is the author of Joint Ventures Involving Tax-Exempt Organizations (3rd Ed., 2007; 4th Ed., 2013) which was recently cited by the majority opinion in the widely covered U.S. Supreme Court decision in Burwell v. Hobby Lobby Stores, Inc. He previously served as an attorney-advisor to the assistant secretary of tax policy at the Office of Tax Legislative Counsel.

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Description

Real estate remains one of the top portfolio items for investors, with thousands of real estate transactions taking place daily. Tax counsel and advisers representing persons in real estate transactions must have a comprehensive understanding of optimal tax planning and structures for the ownership vehicle and the mechanics of the purchase or sale transaction.

For income tax purposes, counsel for buyers and sellers should be prepared to address the tax consequences of various transactions and entity structures, plus the related tax compliance requirements. Tax counsel and advisers must be well versed in the allocation of the purchase price to buyers and sellers, tax considerations for entity versus asset purchases, tax elections under IRC Sections 338 and 754, and the use of 1031 exchanges and qualified opportunity funds (QOFs).

For foreign investors, balancing a variety of tax issues to determine the appropriate ownership vehicle for U.S. property is essential to optimum tax planning. Various ownership structures--whether direct ownership by a non-U.S. person or use of a foreign or domestic corporation, trust, or partnership--each have particular tax consequences for the foreign owner. In addition to entity selection, there are various opportunities and pitfalls in structuring the purchase transaction.

Listen as our panel of tax practitioners goes beyond the basics to provide a comprehensive and practical guide to structuring real estate transactions for tax planning, strategies for maximizing favorable capital gains tax treatment, aggregating rental properties, grouping strategies, and other key tax planning considerations.

Outline

  1. Tax implications of buying and selling real estate
  2. Tax consequences of various acquisition and ownership structures
  3. Purchase price allocation considerations
  4. Tax strategies for structuring the deal including 1031s and QOFs
  5. Tax issues and opportunities for foreign investors

Benefits

The panel will review these and other key issues:

  • What are the tax implications for buyers and sellers in real estate transactions?
  • What are the key considerations for determining the appropriate entity structure for purchasing real estate?
  • How do you handle purchase price allocations for the buyer and seller?
  • What are the various tax consequences of a foreign person owning U.S. real estate in an individual capacity?
  • What is the impact of blocker corporations and other intermediary entities on the tax treatment of foreign investment in U.S. real estate?
  • How can you utilize 1031 exchanges and QOFs, and what are the current tax rules to consider?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify ownership structures and related tax consequences for investments and structures for real estate transactions
  • Understand the considerations in determining the optimal purchasing entity for domestic and foreign investors in U.S. real estate
  • Ascertain tax planning opportunities in structuring real estate transactions

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of pass-through taxation, including taxation of partnerships, S corporations and their respective partners and shareholders. Familiarity with different types of ownership entities and structures and related tax consequences for buyers and sellers of real estate.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).