Partnership Exchanges: Structuring "Drop and Swap" and "Mixing Bowl" Transactions
Minimizing the Risk of an Unfavorable Audit Outcome
Recording of a 90-minute CLE/CPE webinar with Q&A
This CLE/CPE webinar will provide tax advisers with knowledge and tools to advise partnership clients looking to convert to a tenancy-in-common form of ownership of real estate. Tax advisers may recommend such a conversion in contemplation of a future sale of property or to create a master limited liability company for various commonly owned real estate entities to allow partners to go their separate ways.
- Overview of Section 1031 partnership asset exchanges
- Drop and swap transaction
- Mixing bowl transaction
The panel will review these and other key issues:
- What are the requirements of IRC Section 1031 on partnership asset exchanges?
- How must you implement the drop and swap transaction to maximize 1031 treatment on the property exchanged?
- How can the mixing bowl technique allow partners to separate their real estate holdings in commonly owned entities without triggering immediate tax?
Todd D. Keator
Thompson & Knight
Mr. Keator represents clients in general tax matters including corporation, partnership, and LLC formation and... | Read More
Mr. Keator represents clients in general tax matters including corporation, partnership, and LLC formation and operation; tax-deferred 1031 exchanges; federal and state tax planning and advice; real estate syndications (TICs, REITs, LPs and LLCs); tax structuring for mergers, acquisitions, divisions and financing; private equity transactions; MLP formation and acquisitions; private toll road development; oil and gas tax; and FIRPTA tax. He provides clients with transactional planning and advice, document preparation, and preparation of tax opinions on federal and state tax implications of business transactions.Close
Strasburger & Price
Mr. Moorefield provides counsel with regard to federal income taxation and structuring complex business transactions... | Read More
Mr. Moorefield provides counsel with regard to federal income taxation and structuring complex business transactions for corporations, partnerships, limited liability companies and other business entities. He has extensive experience in complex business restructurings, including those involving distressed corporations and partnerships, as well as matters related to complex debt and equity instruments. He also has significant experience in structuring tax-advantaged asset monetizations, including publicly traded partnerships, royalty trusts, real estate investment trusts and other tax-deferred asset disposition strategies. Other significant portions of his practice involve taxation of oil and gas, timber and real estate investments and financial derivatives. He has written and lectured on partnerships, bankruptcy and real estate taxation.Close
Mark E. Wilensky
Meltzer Lippe Goldstein & Breitstone
Mr. Wilensky focuses his practice on tax law, with a significant part of his practice advising clients looking to sell,... | Read More
Mr. Wilensky focuses his practice on tax law, with a significant part of his practice advising clients looking to sell, exchange, lease, or refinance real estate and take advantage of the tax deferral opportunities offered by section 1031 exchanges, installment sales, and long-term lease agreements. He frequently advises clients operating as partnerships, limited liability companies, or S corporations on ways to achieve tax deferral from an exchange of property without triggering gain from receipt of taxable “boot.” He also counsels business entities on ways to divide a business among shareholders or partners without triggering taxable gain or otherwise counseling clients operating as limited liability companies or S corporations on ways to take advantage of the lower tax rates on capital gains when selling all or a portion of a business.Close