| Attend upcoming webinar and earn continuing education credits. | Partnership Exchanges After Tax Reform: Structuring "Drop and Swap" and "Mixing Bowl" Transactions | | | | | | | | April | | | | 8 | | 1 pm - 2:15 pm ET | | | Presenters: Bradley Borden, and Marie Flavin | | | Credits: CPE, CLE in all states (Credit Details) | | | Can't attend live? By registering, you will be able to view the course live, view a recording at any time after the live presentation, or both. | | | Viewing Options: View on your computer, tablet, or smartphone | | | | | | | | | | | | In this practical webinar, you will be equipped with the knowledge and tools to advise clients on the advanced section 1031 exchange structures in light of the 2017 legislation and recent regulatory guidance. These advanced exchange structures include dividing a partnership in proximity to an exchange ("drop-and-swap") or forming a partnership following an exchange ("swap-and-drop"). These rules implicate aspects of IRC 1031 and provisions of subchapter K. Some members of legacy corporations that own real property also look to do section 1031 exchanges, but such arrangements are subject to the corporate tax regime, complicating proximate restructuring and exchanging. The "drop and swap" technique can be implemented by members of partnerships who wish to sell the partnership property and go their separate ways, but also retain the option of doing a section 1031 exchange. Such transactions also come with substantial complexities and risks. You will learn about the rules that property owners and their advisors must navigate to ensure the break-up and exchange qualify for nonrecognition under section 1031. "Mixing bowl" structures potentially allow partners to separate their interests in multiple real estate entities on a tax-deferred basis by first consolidating commonly owned entities into a master limited liability company and subsequently liquidating that company. You will learn how to prepare for significant complexities when implementing a mixing bowl structure, including the disguised sale and anti-mixing bowl provisions of the Internal Revenue Code. In this practical webinar, you will review the drop and swap and mixing bowl techniques for purposes of tax-free or tax-deferred partnership asset exchanges. You will examine best practices in structuring these transactions to maximize IRS recognition of the desired tax treatment and minimize challenges. Topics to be covered include: - Section 1031 changes in the 2017 legislation and recent guidance related to section 1031 exchanges
- Drop-and-swap transaction
- Drop-swap cash-outs
- Swap-and-drop transactions
- Mixing-bowl transactions
- Corporations and drop-swap transactions
Upon course completion, you will be able to: - Outline the requirements of section 1031 on partnership asset exchanges
- Describe the impact of tax reform on the use of section 1031 for certain assets
- Implement the drop-and-swap transaction to maximize section 1031 treatment on the property exchanged
- Utilize the mixing-bowl technique to allow partners to separate their real estate holdings in commonly owned entities without triggering immediate tax
- Advise owners of corporations on how to combine a corporate division with a section 1031 exchange
| | | | | | | | | | Bradley T. Borden is a Professor of Law at Brooklyn Law School. He teaches Federal Income Taxation, Partnership Taxation, Taxation of Real Estate Transactions, and Unincorporated Business Organizations. Prior, he practiced law at Oppenheimer, Blend, Harrison & Tate, Inc., in San Antonio, Texas. He also frequently works as an expert witness or consultant in cases related to partnership and real estate taxation and other aspects of partnerships and LLCs. Mr. Borden is the author of several books and numerous articles in leading tax and legal journals, including FEDERAL TAXATION OF CORPORATIONS AND CORPORATE TRANSACTIONS (Aspen Publishers 2018, with Steven A. Dean) and Business Entities, The Journal of Taxation, Probate and Property, Real Estate Finance Journal, Real Estate Taxation, Tax Management Real Estate Journal, and Tax Notes. Mr. Borden is a fellow of the American Bar Foundation and the American College of Tax Counsel. He earned a B.B.A. and M.B.A. from Idaho State University and a J.D. and LL.M. in taxation from University of Florida Fredric G. Levin College of Law. He is licensed to practice law in New York and Texas, and he is a certified public accountant. | |  | | | | | | | Marie C. Flavin, Esq., Senior Vice President and Northeast Regional Manager of Investment Property Exchange Services, Inc. (IPX), is a member of the New York and Connecticut Bars, and has practiced real estate law for over 27 years, while specializing in 1031 exchanges with IPX for over 20 years. Ms. Flavin frequently lectures and writes articles on IRC § 1031 tax deferred exchanges. She is an adjunct professor at the University of New Haven, where she teaches Business Law. She received her B.A. from St. John's University and her J.D. from St. John's School of Law. | | | | | | | | | | | ● Earn continuing education credit for no additional fee
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