Partnership Allocations for Real Estate Entities: Special Allocations, Section 704(b) DROs and QIOs, Nonrecourse Debt
Recording of a 110-minute CPE webinar with Q&A
This webinar will explain meeting tax compliance obligations for partnership allocations to LLC members and partners. Our authoritative panel of real estate professionals will break down the complex rules for nonrecourse deductions, special allocations, and 704(b) compliance for tax advisers working with real estate investors.
Outline
- Partnership allocations for real estate entities: introduction
- Section 704(b), substantial economic effect
- Special allocations
- Nonrecourse deductions
- Minimum gain
- Section 469, passive loss limitations
- At-risk limitations
- Recapture of losses
Benefits
The panel will cover these and other critical issues:
- Meeting the substantial economic effect provisions of Section 704(b)
- Calculating minimum gain and minimum gain chargeback
- Identifying targeted allocations in partnership agreements
- Caveats of nonrecourse debt for real estate investors
Faculty
Alan M. Blecher, JD
Managing Director
CBIZ Marks Paneth
Mr. Blecher has considerable experience serving high-income and high-net-worth individuals and their closely held... | Read More
Mr. Blecher has considerable experience serving high-income and high-net-worth individuals and their closely held businesses. He focuses especially on partnerships, limited liability companies and S corporations.
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David A. Gilbert
Of Counsel
Blank Rome
Mr. Gilbert represents domestic and international clients in a wide range of federal, state, and local tax matters. He... | Read More
Mr. Gilbert represents domestic and international clients in a wide range of federal, state, and local tax matters. He advises publicly-traded and private corporations, partnerships, funds, tax-exempt organizations, and individuals on various matters, including those arising in:
taxable and tax-free mergers and acquisitions
divestitures, restructurings, spin-offs, redemptions, and liquidations
inbound and outbound investments
formation, operation, and acquisition of limited liability companies, partnerships, and Subchapter S corporations
real estate transactions
financings
tax controversies
Mr. Gilbert also has experience advising private equity and hedge fund sponsors on the tax aspects of fund formation as well as representing institutional investors in connection with joint ventures and other investments.
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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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