To give CPAs and other tax professionals the technical skills to service real estate partnerships. You will gain a deeper understanding of the business of real estate formation, finance and operation. You'll be able to identify relevant tax issues and plan aggressively for your company or clients.
DETAILED LEARNING OBJECTIVES
• Identify factors influencing choice of entity for real estate ownership
• Understand partnership taxation as a flow-through system
• Recognize which entities are subject to double taxation
• Recall why partnerships are the preferred entity for real estate
• Distinguish between partnership-level and partner-level tax decisions
• Identify allowable methods of accounting for partnerships
• Determine which partnerships may use the cash method of accounting
• Recall gross receipts threshold for cash method eligibility with a C Corp partner
• Recognize when a partnership is considered a tax shelter under §448
• Recall time frame that creates a presumption of disguised sale under §721
• Understand when liabilities on contributed property trigger gain recognition
• Calculate gain recognition when liabilities are shared upon contribution
• Recall rules for taxation of services exchanged for a capital interest
• Identify factors determining a partner’s basis in partnership interest
• Apply §704(c) to determine contributing partner’s recognized gain
• Apply §704(c) to determine non-contributing partner’s recognized gain
• Distinguish between inside basis and outside basis of a partnership interest
• Identify events that increase a partner’s outside basis
• Identify events that decrease a partner’s outside basis
• Recall that recourse debt allocations are based on constructive liquidation
• Recognize characteristics of recourse debt
• Identify characteristics of nonrecourse liabilities
• Recall assumptions under final §752 regulations for payment obligations
• Identify which tier allocates nonrecourse debt equal to pre-contribution gain
• Recognize criteria that create disguised sale treatment under §707
• Recall requirements for allocations to have substantial economic effect under §704(b)
• Recall time limit for deficit restoration under §704(b) safe harbor rules
• Identify items that increase book capital accounts under §704(b)
• Recognize which partners are typically subject to qualified income offset rules
• Recall initial allocation of nonrecourse debt to minimum gain under §704(b)
• Understand that §704(c) allocations may use reasonable methods
• Recall acceptable methods for applying §704(c)
• Understand purpose of a §754 election in partnership taxation
• Recall mechanics of §754 step up in basis calculations
• Recall timing and filing requirements for making a §754 election
• Recall how OBBBA modifies the business interest deduction limitation
• Recall recognition rules for advance rent under accrual method
• Recall recognition rules for advance rent under real estate rental income rules
• Recall standard MACRS life for nonresidential property
• Recall standard MACRS life for residential rental real estate
• Recall rental threshold for §467 deferred rent rules
• Recognize when tenant security deposits become taxable income
• Recall holding period for profits interest under §1061
• Recall timing requirements for identifying and closing on replacement property under §1031
• Identify acceptable qualified intermediaries for §1031 exchanges
• Recall reinvestment requirement for gain deferral under §1033 involuntary conversions
• Identify common events that trigger foreclosure
• Distinguish characteristics of recourse mortgages
• Define insolvency for tax purposes
• Recall exceptions for excluding CODI under §108 including QRPBI
• Recognize disadvantages of using a C Corporation for real estate ownership
• Recall OBBBA treatment of bonus depreciation for property placed in service after January 19, 2025
• Recall ADS requirement when electing out of business interest limitation for real property businesses
• Recall safe harbor requirement to maintain capital accounts under §704(b)
• Recall gain and CODI treatment when foreclosure involves recourse mortgage
