Real Estate Loan Workouts: Tax Opportunities and Risks
Strategies to Minimize Tax Liability in Commercial Loan Restructurings
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This seminar will examine the tax opportunities and pitfalls inherent in commercial real estate loan workouts and will provide legal strategies for owners, developers and lenders involved in negotiating workout agreements.
Outline
- Real estate loan workouts—introduction
- Tax considerations
- COD income
- Qualified real property business indebtedness
- Section 108(i)—Election to defer COD income under American Recovery and Reinvestment Act of 2009
- Partnerships
- Foreign owner/debtor
Benefits
The panel will review these and other key questions:
- What are the potential tax consequences of modifying troubled commercial real estate loans?
- How does the new taxpayer relief in the American Recovery and Reinvestment Act impact real estate loan workouts?
- What unique tax issues arise when the commercial real estate loan to be modified is held by a partnership?
Faculty
Mark Stone
Partner
Holland & Knight
He practices in the area of corporate, international, and real estate taxation. He has represented complex real estate... | Read More
He practices in the area of corporate, international, and real estate taxation. He has represented complex real estate partnership/LLCs in tax matters arising out of refinancing of hotels and office buildings and restructuring of the underlying ownership interests, and other clients in corporate reorganizations, state and local taxation, stock options and other matters.
CloseMichael Hirschfeld
Partner
Dechert
He is a tax partner who focuses his practice on corporate, international, leasing, real estate, workouts, and... | Read More
He is a tax partner who focuses his practice on corporate, international, leasing, real estate, workouts, and partnership matters. He is Chair of the Federal Taxation of Real Estate Committee of the American Bar Association's Real Property Section. He speaks and writes frequently on tax topics.
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