Join the MSBA Taxation Law Section and the MACPA for Advanced Tax Institute (ATI) Day 2: Real Estate & Partnerships!
This program has been the must-attend educational event for lawyers and CPAs in Maryland for almost 20 years. ATI is the only program in Maryland focused on complex tax issues for business and individuals in four different areas: Current Tax Issues and Business Tax Update, Real Estate & Partnerships, Estate Planning Issues and State and Local Tax.
With our partners at MACPA, we are proud to bring national and statewide speakers and faculty to Maryland attorneys to enrich your practice.
2024 Advanced Tax Institute (ATI) – Day 2
Real Estate & Partnerships Agenda
8:30 a.m. – 9:45 a.m. Related Party Basis Shifting Transactions and New Form 7217 | Ryan Dobens, CPA, M.S., J.D. Senior Manager, Ernst & Young, LLP and Andrew Cohn, CPA, Partner, Ernst & Young, LLP
This session will identify, review, and consider related party basis shifting transactions as described by IRS Notice 2024-54, REG-124593-23, and Rev. Rul. 2024-14. The impact of this guidance, if finalized in its current form, would drastically implicate many common partnership transactions. This session will also discuss the AICPA’s comment letter on the related party basis shifting transaction guidance and cover new partnership distribution disclosures on IRS Form 7217.
9:45 a.m. - 11:00 a.m. Energy Transition + Real Estate = Success (Real Estate meets Energy Transition)|Steven Schneider, LL.M., J.D., Partner, Hogan Lovells US, LLP and Stephen Weinstein, Senior Associate, Hogan Lovells US, LLP
11:00 a.m. - 11:15 a.m. Break
11:15 a.m. - 12:15 p.m. Post-Election Legislative Outlook: Real Estate Taxation | Ryan McCormick, J.D., Senior Vice President & Counsel, Real Estate Roundtable
This session will identify, review, and consider key real estate tax issues likely to arise in the new Congress and Administration. What are the major tax policy challenges and opportunities for U.S. real estate and the real estate industry? How will the recent election influence tax legislation going forward? More specifically, what changes in tax policy could occur over the next two years, and how will those reforms affect U.S. real estate? Topics we will discuss include capital gains and gains-related proposals, such as: increasing the capital gains rate, taxing unrealized gains, ending the deferral of gain through like-kind exchanges, ending step-up in basis and taxing gains at death, changing the capital gains treatment of carried interest, and reforming the treatment of foreign investors' real estate gains. Other topics will include potential reforms of partnership and pass-through tax rules, the future of sections 199A, the net investment income tax, and bonus depreciation. The session will also consider the outlook for important housing (LIHTC), community development (Opportunity Zones), and clean energy incentives, in addition to new and novel proposals such as a federal tax credit for commercial-to-residential property conversions.
12:15 p.m. - 1:15 p.m. Lunch
1:15 p.m - 2:15 p.m Partnership Tips and Tricks - Things Practitioners Need to Know | Megan A. Stoner, Esq.
2:15 p.m. - 3:15 p.m. Complexity and Planning: the Grouping and Aggregation Rules Under Sections 469, 1411, 199A, and 465 | Paul H. Wilner, CPA, Advisor, Grossberg Company
The grouping, and the definition, of activities can be different under different sections of the law. These differences can result in material variances in the tax treatment of the same items of income and deduction, causing complexity and confusion in proper reporting. For example, aggregation of separate activities and/or flow through entities under the at-risk rules may be applied under different rules than passive activity grouping or the grouping of activities under Section 1411 tax (“NIIT”). Further, the aggregation rules under Section 199A are different than those under Section 465 but are similar to those under Section 469 (with certain exceptions). The differences in how these rules are applied create complexities and material tax differences when reporting on tax returns. This session discusses the issues under these varying grouping rules.
3:15 p.m. - 3:30 p.m. Break
3:30 p.m. - 4:45 p.m. Sale of Partnership Interests, Including Implications of Rawat v. Commissioner | Norman Lencz, Esq., Partner, Venable, LLP, Christopher Davidson, LL.M., J.D., Partner, Venable, LLP, Christopher Moran, J.D., Counsel, Venable, LLP
Sales of partnership interest often involve complex tax issues, and this presentation will provide an overview of these tax issues, as well as planning ideas for the tax-efficient structuring of partnership interest sales. The implications of the recent case of Rawat v. Commissioner will also be discussed.
4:45 pm Program Adjourns
6.5 hours of credit with the surrounding MCLE states will be offered per day.
Price: $325 (Member/ Non-Member)
Register to attend other days virtually or view the full conference below:
Day 2 | Real Estate & Partnerships
Day 3 | Estate Planning Issues
Day 4 | State and Local Tax Day
Want to attend in-person? View whole conference here
*Multi-day discount is automatically available once multiple days are added to your cart.
Electronic Material Notice:
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.
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Price: $325 (Member/ Non-Member)