Capital Gains Tax Planning for Real Estate Transactions: Tax Allocations, IRC 338 and 754 Elections, IRC 1031, QOFs
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE webinar will provide tax counsel and advisers with a thorough and practical guide to structuring and tax planning strategies specifically for maximizing favorable capital gains tax treatment for real estate transactions. The panel will outline best practices for determining the purchasing entity and review tax planning opportunities to structure the deal and other key tax planning items.
Outline
- Tax implications of buying and selling real estate
- Determining the purchasing entity structure
- Entity vs. asset purchases
- Tax allocations for buyer and seller
- IRC Sections 338 and 754 elections
- 1031 exchanges and QOFs
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?
- What are the differences and key issues of entity purchases versus asset purchases?
- How do you handle tax allocations for the buyer and seller?
- What are the pros and cons of making a Section 338 or 754 election?
- How can you utilize 1031 exchanges and QOFs, and what are the current tax rules to consider?
Faculty
Kurt Koegl, CPA
Managing Director
CBIZ
Mr. Koegl is a Managing Director in our New York City office and specializes in the real estate industry. He... | Read More
Mr. Koegl is a Managing Director in our New York City office and specializes in the real estate industry. He has served clients with a broad mix of operations, including residential, commercial, hospitality, mixed use, infrastructure, real estate backed financial instruments, and construction. Mr. Koegl has experience with public and private REITs, traditional real estate funds, private equity, fund of funds, venture capital, Fortune 500 public companies, inbound and outbound foreign investments, domestic, international, state and local tax compliance, reporting, planning, and structuring. He works closely with his clients to manage tax compliance and analyze, research, discuss, plan, and memorialize tax policy and positions. Mr. Koegl assists clients in planning or reviewing existing client structures for foreign, federal, and state tax expense, exposure, efficiency, and filing requirements. Prior to joining the Firm, he was a senior manager at a Big Four accounting firm in the New York real estate tax practice, where he served public and private clients with a specialization in real estate funds and REITs.
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Michael I. Sanders
Partner
Blank Rome
Mr. Sanders focuses his practice in the area of taxation, particularly in matters affecting partnerships, limited... | Read More
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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Brian Senie
Partner
Kirkland & Ellis
Mr. Senie advises clients on tax issues arising in real estate transactions and related transactions involving... | Read More
Mr. Senie advises clients on tax issues arising in real estate transactions and related transactions involving partnerships, REITs and qualified opportunity zone funds, including mergers, acquisitions, financings, restructurings and fund formation. He has provided counsel for private equity sponsors, publicly traded corporations and REITs in a variety of sectors ranging from multi-family residential, office and retail to lodging, gaming, healthcare and insurance.
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