Southern Federal Tax Institute Southern Federal Tax Institute 2107 North Decatur Road, PMB 521, Decatur, Georgia 30033
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Business Taxation

TUESDAY MORNING, OCTOBER 21, 2014
James B. Sowell, Presiding

PARTNERSHIPS AND REAL ESTATE


7:15-8:15 Breakfast
8:15-9:05 HOT TOPICS IN PARTNERSHIP AND REAL ESTATE TAXATION – This session will provide you with the information you need to stay current in partnership and real estate taxation. Topics to be covered will likely include proposed regulations dealing with mandatory partnership downward basis adjustment rules enacted by the American Jobs Creation Act of 2004; current developments with respect to the tax treatment of management fee waivers; the new IRS safe harbor provided in Revenue Procedure 2014-12 relating to section 47 rehabilitation credit partnerships; the Tax Court’s Pilgrim’s Pride Corp. decision and what it means for those who have taken, or wish to take, an ordinary loss on abandonment of an interest in a distressed real estate partnership; and a review of so-called “payment in lieu of taxes” (PILOT) programs and similar “bonds for title” structures that are intended to reduce or eliminate ad valorem property taxes for newly developed real estate, including the federal income tax consequences that flow therefrom.
Pardis Zomorodi, Latham & Watkins LLP, Los Angeles, CA
9:05-10:05 YOU THOUGHT YOUR 1031 EXCHANGE WAS ON AUTOPILOT BUT THE CREW FELL ASLEEP: A COMPENDIUM OF CLASSIC 1031 BUSTS – A review of common section 1031 screw-ups, including disqualified person QI traps; paragraph (g)(6) violations; identifying the wrong entities; identifying too many properties; documentation errors and oversights; failure to spot potential boot issues; now you see it now you don’t co-tenancies; and related party disposition issues.
Adam M. Handler, PricewaterhouseCoopers LLP, Los Angeles, CA
Mary Cunningham, Chicago Deferred Exchange Company, Chicago, IL
10:05-10:20 Break
10:20-11:10 IT WASN’T BROKE BUT THEY FIXED IT: COPING WITH THE NEW SECTION 752 LIABILITY ALLOCATION REGIME AND TRANSITION
RULES
- Analysis of new section 752 rules and their effect on tax structuring of partnership roll-ups; impact on existing partnership debt allocation arrangements; impact on disguised sale planning.
John J. Rooney, KPMG LLP, Washington, DC
11:10-12:00 AN ABC PRIMER ON TIMBER TAXATION FOR TAX ADVISORS WHO HAVE TROUBLE SEEING THE FOREST AND THE TREES – Don’t be intimidated by arcane timber industry jargon any longer. This program will cover basic types of timber contracts and timber industry terminology; how to structure contracts to achieve capital gain under section 631; basic depletion concepts; tax treatment of timber gains under FIRPTA and UBTI rules; tax planning issues for timber REITs.
Daniel R. McKeithen, Sutherland Asbill & Brennan LLP, Atlanta, GA
12:15-1:05

Mid-day Program

TUESDAY AFTERNOON, OCTOBER 21, 2014
Stephen R. Looney, Presiding
CORPORATIONS

1:15-2:15 SECTION 351: TRAPS AND OPPORTUNITIES – Review of various tax issues, potential pitfalls and planning opportunities encountered in section 351 transactions, including a discussion of step-transaction issues affecting the “control” requirement; springing liabilities in check-the-box elections and other section 357(c) issues; dealing with investment company issues under section 351(e); and use of section 351 to achieve tax-free treatment in management rollover and other acquisition transactions.
Martin Huck, Ernst & Young LLP, Washington, DC
2:15-3:15 TAX CONSIDERATIONS FOR BUYERS AND SELLERS OF S CORPORATIONS – Selected tax issues faced by buyers and sellers of S corporations in taxable and tax-free transactions. Issues discussed will include elections under section 338(h)(10) and section 336(e); dealing with the built-in gains tax; installment sales, sale of qualified Subchapter S subsidiaries and particular considerations related to acquisition of C corporations by S corporations.
Eric M. Elfman, Ropes & Gray LLP, Boston, MA
3:15-3:30 Break
3:30-4:30 DEALING WITH STATE AND LOCAL TAX ISSUES IN CORPORATE ACQUISITIONS - This presentation will address significant state and local tax aspects of corporate acquisitions, including important areas of focus in due diligence, rules governing the sourcing of gain, the effect of acquisitions on state tax attributes, successor liability concerns, and the availability of sales and use tax exemptions.
Bruce P. Ely, Bradley Arant Boult Cummings LLP, Birmingham, AL
Peter G. Stathopoulos, Bennett Thrasher PC, Atlanta, GA
4:30-5:30 WHAT TO DO WHEN YOUR CLIENT HAS VALUABLE REAL ESTATE TRAPPED IN A C CORPORATION? – C to REIT conversions; the ABC’s of living with a REIT; built-in gains tax issues; conversion to S corporation status; tax-free spin-offs (including the Penn National ruling and the prospects for similar transactions).
Michael Mollerus, Davis Polk & Wardwell LLP, New York, NY
5:45-7:45 FLORIDA CPA REQUIREMENTS FOR ETHICS IN TAX PRACTICE– Covers the ethical standards for tax practice for CPAs, including an overview of Circular 230, discussion of key provisions with examples, state accountancy rules for ethics, and the AICPA ethical guidelines in Statements on Standards for Tax Services. For Florida CPAs only.
 
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