Federal Real Estate and Partnerships Tax Conference Agenda

Kathleen Costello, CMP, Assistant Director, NYU School of Professional Studies, New York, NY

The Section 752 partnership liability allocation rules present planning opportunities; this presentation explores the regulations and transactions, and cases in which the Section 752 regulations apply.

Andrea M. Whiteway, Esq., Principal, EY, Washington, DC

This presentation explores the various planning techniques available to real estate entrepreneurs in the estate planning context.

Stephen M. Breitstone, Esq., Partner, Meltzer, Lippe, Goldstein & Breitstone, Mineola, NY and New York, NY
Jerome M. Hesch, Esq., Counsel, Meltzer, Lippe, Goldstein & Breitstone, Boca Raton, FL
Joseph Medina, CPA, Managing Director, EY, Washington, DC

A panel discussion regarding the basic requirements, recent regulatory updates, and the real world aspects of investments in opportunity zones; as well as recent legislative proposals impacting opportunity zones.

Brian J. O’Connor, Esq., Partner, Venable, Washington, DC
Paul H. Wilner, CPA, Partner, Grossberg Company, Bethesda, MD

This session provides an outstanding opportunity for the audience to raise tax questions with a panel of leading experts.

Brian J. O’Connor, Esq., Partner, Venable, Washington, DC
Robert D. Schachat, Esq., Managing Director, BDO USA, Washington, DC
Steven R. Schneider, Esq., Partner, Stroock & Stroock & Lavan, Washington, DC
Andrea M. Whiteway, Esq., Principal, EY, Washington, DC
Paul H. Wilner, CPA, Partner, Grossberg Company, Bethesda, MD

This session covers creative real estate deal structures related to transactions involving the formation of joint ventures with appreciated property or built-in loss property, contributions by non-owners (government subsidies, grants, and TIFs), recapitalizations, book-ups, bookdowns, preserving negative capital accounts, conversion of debt into equity, and similar taxdriven transactional planning.

Brian J. O’Connor, Esq., Partner, Venable, Washington, DC
Steven R. Schneider, Esq., Partner, Stroock & Stroock & Lavan, Washington, DC

This panel covers a wide variety of recent developments impacting like-kind exchanges of real property, including related party transactions, leases, parking arrangements within and outside the safe harbor, construction exchanges, and refinancing before or after the exchange and foreclosures.

Glenn M. Johnson, Esq., Principal, EY, Washington, DC
Robert D. Schachat, Esq., Managing Director, BDO USA, Washington, DC

An overview of recent and pending developments in partnership and real estate taxation from the government perspective. This is an opportunity to hear firsthand the view of a key government official about what’s important, why it’s important, and what the government is doing about it.

Holly Porter, Esq., Associate Chief Counsel (Passthroughs and Special Industries), Internal Revenue Service, Washington, DC
Andrea M. Whiteway, Esq., Principal, EY, Washington, DC
Paul H. Wilner, CPA, Partner, Grossberg Company, Bethesda, MD

Join your fellow attendees for an opportunity to meet the speakers and to network with tax practitioners from around the country.

The presenter discusses the mechanics of Section 704(c) and reverse Section 704(c) allocations: the traditional method, ceiling limitation principles, traditional method with curative allocations, remedial allocation method, various operating rules in the Section 704(c) regulations, Section 704(c)(1)(C); anti-abuse provisions, tax distribution considerations, and planning concepts.

Paul H. Wilner, CPA, Partner, Grossberg Company, Bethesda, MD

Given the impact of the Pandemic on business, understanding how to navigate the federal income tax issues associated with debt forgiveness and workouts is more important than ever. This presentation covers the issues associated with troubled businesses and debt restructuring/workouts with a focus on partnerships and real estate.

Audrey W. Ellis, Esq., Principal, PricewaterhouseCoopers, Washington, DC
James B. Sowell, Esq., Principal, KPMG, Washington, DC

This session explores the treatment of deferred revenue in partnership transactions, including distributions of the associated cash, transfers of interests in partnerships that have deferred revenue, and contributions to partnerships that have deferred revenue.

Steven Gilbert, Esq., Managing Director, Deloitte Tax, Washington, DC
Jennifer Ray, Esq., Principal, Deloitte Tax, Washington, DC

This presentation focuses on current key national public policy issues and legislative actions under consideration as they affect the real estate industry as well as the overall economy.

Ryan P. McCormick, Esq., Senior Vice President and Counsel, The Real Estate Roundtable, Washington, DC

This presentation discusses how to structure foreign investment in US real estate, joint ventures with offshore investors, debt versus equity structures and withholding requirements and traps.

David Friedline, Esq., Partner Deloitte Tax, New York, NY
Michael Hirschfeld, Esq., Managing Director, Andersen Tax, New York, NY

This panel addresses issues arising in leasing transactions; including identifying a true lease, tax issues that arise with stepped or deferred rent, leasehold improvements, landlord work letters and other inducements, and tax treatment of lease terminations.

Glenn M. Johnson, Esq., Principal, EY, Washington, DC
Robert D. Schachat, Esq., Managing Director, BDO USA, Washington, DC