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TUESDAY MORNING, SEPTEMBER 23, 2008
PARTNERSHIPS AND REAL ESTATE |
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| 07:30-08:30 |
Breakfast |
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| 08:30-09:45 |
HOT TOPICS IN PARTNERSHIP AND REAL ESTATE TAXATION – This presentation will address a number of important issues affecting partnership taxation, including the current state of play with respect to carried interests and other compensatory partnership interests, Countryside, Jade Trading, and business purpose in partnership transactions, guidance regarding substantial economic effect, and evolving issues relating to disguised sales.
James H. Lokey, Jr., King & Spalding LLP, Atlanta, GA | |
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| 09:45-10:00 |
Break |
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| 10:00-11:00 |
COMING TOGETHER AND BREAKING APART: PLANNING AND PITFALLS IN PARTNERSHIP MERGERS AND DIVISIONS – Although the economic transactions are fairly straightforward, the tax analysis in a partnership merger or division is anything but simple. Assets and liabilities that you think are moving one way may be treated as moving, for tax purposes, in a completely different direction, causing radically different tax results. And the impact of other partnership provisions on a merger or division can be very complicated, as evidenced by recently proposed regulations relating to §704(c) and partnership mergers. This presentation will attempt to bring some rationality to all the madness.
Cassady V. Brewer, Morris, Manning & Martin, LLP, Atlanta, GA |
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| 11:00-12:00 |
PRIMER ON PASSIVE LOSS RULES AND AT-RISK RULES – These rules are not always “front of mind” when undertaking a transaction, but often they should be. This presentation will focus on practical issues (and the problems) that can arise under these rules and how, with advance planning, these issues can be dealt with. The presentation also will include a discussion of audit issues currently being raised by the IRS.
Amy L. Sutton, Deloitte Tax LLP, Houston, TX |
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| 12:15-01:05 |
Mid-day
Program on a topic to be announced. Sponsored
by THE SHAFE GROUP |
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TUESDAY AFTERNOON, SEPTEMBER 23, 2008
REAL ESTATE AND CORPORATIONS
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| 01:15-02:15 |
SWAPPING WITH FAMILY MEMBERS AND SWAPPING PERSONAL RESIDENCES: RELATED PARTY 1031 EXCHANGES PLUS EXCHANGES OF VACATION HOMES – Section 1031(f) did not mark the end of related party tax-deferred §1031 exchanges. Numerous opportunities continue to exist, some of which have been explicitly (and somewhat surprisingly) sanctioned by the IRS. This presentation will cover the current cutting-edge transactions involving related party 1031 exchanges, including the utilization of losses between related parties to minimize or avoid the impact of §1031(f). It will also cover the issue of swapping vacation homes, which has come to the forefront with the promulgation of Rev. Proc. 2008-16.
Terence Floyd Cuff, Loeb & Loeb LLP, Los Angeles, CA |
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| 02:15-03:15 |
CURRENT ISSUES IN THE TAXATION OF C CORPORATIONS – This presentation will discuss the new continuity of business enterprise regulations (COBE) and the §1.368-2(k) regulations; the new active trade or business regulations issued under §355(b)(3); all cash “D” reorganizations; recent cases that impact routine business transactions – Coltec; Heinz; Jade Trading; Countryside Limited Partnership.
R. David Wheat, Thompson & Knight LLP, Dallas, TX,
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| 03:15-03:30 |
Break sponsored by INVESTORS TITLE EXCHANGE CORPORATION |
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| 03:30-04:30 |
HOT
TOPICS IN S CORPORATIONS – This presentation
will focus on recent legislative changes, employment
tax issues, §1374 developments, and trusts as S
corporation shareholders.
Stephen R. Looney, Dean, Mead, Egerton, Bloodworth,
Capouano & Bozarth, P.A., Orlando, FL
Ronald A. Levitt, Sirote & Permutt,
P.C., Birmingham, AL
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| 04:30-05:30 |
GETTING APPRECIATED ASSETS OUT OF CORPORATE SOLUTION – Nobody likes two levels of tax, but what options are available when assets are held in a C corporation? This presentation will focus on the use of partnerships to allocate earnings and appreciation away from the C corporation and to the ultimate business owners. The presentation also will discuss entity elections (like S corporation, REIT, and RIC) that can effectively create pass-through treatment for the existing entity, but that can carry additional operational issues and a delay (i.e., under §1374) in favorable treatment for asset sales.
S. Barksdale Penick, Ernst & Young LLP, Washington, DC |
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| 06:30-08:30 |
NC CPA REQUIREMENTS FOR ETHICS IN TAX PRACTICE – Covers the ethical standards for NC tax practice for CPAs, including an overview of Circular 230, discussion of key provisions with examples, NC Accountancy rules for ethics, and the AICPA ethical guidelines in the Statements on Standards for Tax Services. For North Carolina CPAs only. |
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