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Advanced Tax Institute 2023 – Real Estate and Partnerships (Day 3)

Description

Join the MSBA Section of Taxation Law and the MACPA for an all new Advanced Tax Institute (ATI) Day 3: Real Estate & Partnerships, November 8th at 8:30 am! 

More details and agenda will be posted soon!

 

Please note – materials for this event will be provided electronically ONLY. Please feel free to bring your own device to view the materials. We recommend that you download them prior to the event date rather than onsite.

 

There will be a $25 fee for changing from IN PERSON format to Virtual after October 23, 2023.

The MSBA is committed to making its programs accessible to all attendees. If you need accommodations please email cle@msba.org.

Course Level
TBD
Professional Area of Focus
Tax Law
Business Law
Real Property
CLE Field of Study
TBD
Location
 
Martin’s West
6817 Dogwood Rd
Baltimore, MD 21244 US
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Event Information
When
Nov 8, 2023
8:30 am - 4:40 pm EST
Location
Martin’s West
6817 Dogwood Rd
Baltimore, MD 21244 US
Total CLE Credits
6.5
Format
In-Person + Webcast Live

Agenda

Day 1

11/08/2023
8:30 am
2023 Advanced Tax Institute (ATI) – Day 3 - Real Estate & Partnerships

8:30 a.m. – 9:45 a.m. Sophisticated Partnership Planning

This session will explore the various partnership anti-abuse rules and disguised sale rules, and discuss techniques available to partners and partnerships to monetize assets, and exit partnerships in a tax efficient manner.

Anrdea Whiteway, Ernst & Young

9:45 am – 11:10 am Section 1031 – Like Kind Exchanges

Developments in like-kind exchanges, related party transactions, construction exchanges, and partnership split-ups.

Robert Schacat, BDO USA

11:00 a.m. – 11:15 a.m. Break

11:15 a.m. – 12:15 p.m. Legislative Updates – What’s Happening in Congress 

and with the Administration

This session will cover the debt ceiling, estate taxes, tax credits, revenue 

raisers, and other topics important to real estate and taxpayers in general have a direct impact on clients’ current and future actions.  

Ryan McCormick, RE Roundtable

12:15 p.m. – 1:15 p.m. Lunch 

1:15 p.m. – 2:15 p.m. Partnerships Traps and Tricks

This session will touch on issues relating to partnership continuations, revaluations, and the classification of partnership indebtedness under section 752. The discussion will consider important consequences of partnership distributions and transfers of interests, including the application of section 751, potential disguised sale transactions, and adjustments to the basis of partnership assets under section 743 and 734. We will also address relevant recent guidance and considerations for 2023 partnership reporting on Form 1065, Schedule K 1.

Megan Stoner, BDO

2:15 p.m. – 3:15 p.m. “Amending” partnership returns – Administrative Adjustment Request

This session will cover the basics of amending federal partnership returns under the centralized partnership audit regime enacted by the Bipartisan Budget Act of 2015.  This session will explore the forms needed to file an administrative adjustment request (AAR), the impact of filing an AAR on the partnership and its partners, and best practices to avoid traps for the unwary.    

Greg Armstrong, KPMG, LLP

3:15 p.m. – 3:30 p.m. Break

3:30 p.m. – 4:45 p.m. Profits Interests

Partnership Profits Interests,” will address the various equity compensation options available to motivate service providers in real estate and private equity partnerships and LLCs, and will include a discussion of the recent Tax Court case, ES NPA Holding LLC v. Commissioner, T.C. Memo 2023-55 (May 3, 2023), regarding the issuance of profits interests in tiered structures.

Norman Lencz, and Chris Davidson, Venable LLC

4:45 pm Program Adjourns

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Advanced Tax Institute 2023 – Real Estate and Partnerships (Day 3)