Part 1:
- Choice of entity considerations – contributions, distributions, and eventual sales
- Acquiring property in a form to minimize taxes later
- Understanding allocation and distribution provisions – layered allocations, target/forced allocations, built-in-gain (or loss) allocations
- Understanding and drafting for continuing ownership, including capital shifts and other shifts in ownership
- Deductions arising from non-recourse debt and minimum gain chargebacks
Part 2:
- Advanced Like-Kind techniques for deferring gain on the disposition of property
- Techniques for using partnerships – mixing bowl partnerships, freeze partnerships, leveraged acquisition partnerships
- Installment sales and cross-purchase/redemption agreements
- Capital gain tax planning and the 3.8% tax on net investment income
Faculty: Saba Ashraf, Ballard Spahr LLP, Philadelphia, PA