Speaking Engagement

John Napoli to speak on the Joint Ventures with Opportunity Funds, Tax-Exempt Investors & REITs panel at the Practising Law Institute’s 14th Annual Real Estate Tax Forum Program

3/19/2012

Practising Law Institute

PLI Center
810 7th Avenue
New York

 

John Napoli to speak on the Joint Ventures with Opportunity Funds, Tax-Exempt Investors & REITs panel at the Practising Law Institute’s 14th Annual Real Estate Tax Forum Program on March 19, 2012.  The program will be held in New York at the PLI Center located at 810 7th Avenue.  

At this annual program, nationally-recognized real estate tax experts will provide attorneys, accountants and real estate professionals with both an overview of the tax laws pertaining to real estate ownership and investment, and a detailed analysis of the most sophisticated and creative tax planning techniques available for structuring, restructuring and unwinding real estate transactions in today’s challenging capital markets. The panel will cover:

  • Current structures and deal terms, including contribution transactions and hope certificates
  • Understanding “series LLCs” and the new proposed regulations
  • 704(c), 707, 737, 752 strategies
  • 752 rules in joint ventures including contingent liabilities and disregarded entities
  • Recent disguised sale cases: Canal Corporation and G-I Holdings
  • Rules on built-in loss properties and mandatory basis adjustments
  • Pulling cash out tax-free in contribution transactions
  • REIT update (including incentive compensation OP Units, LTIPs)
  • Partnership equity for services regulations
  • Avoiding UBIT (fractions rule issues)
  • Structures for avoiding UBIT & bad REIT income (including parking income issues)
  • Phantom income solutions (including clawbacks)
  • Ethical issues

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