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Jeremiah Long Memorial
National Conference
on Like-Kind Exchanges
Under Section 1031 IRC
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2010
Schedule
Wednesday,
October 20
Overview
(Schedule for Conference Intensives
and Advanced reflects 2009 courses
Check back for 2010 Schedule)
Wednesday, October 20
Conference
Intensives
Thursday & Friday,
October 21 & 22
Advanced
2 Day
|
OVERVIEW
Wednesday,
October 20, 2010
Presented
by Mary Foster and Marty Verdick |
|
8:00 am |
Registration &
Continental Breakfast. |
|
8:30 am |
Overview and
Statutory Requirements of §1031 I.R.C.
● The
qualified purpose requirement: Dealer property,
personal residences and vacation homes
● The
like-kind requirement: Real vs. personal
● The
exchange requirement.
● Same
taxpayer requirement: Changing entities
mid-exchange
● Related
Party Rules: Acquiring replacement property from
or selling relinquished property to a related
party |
|
10:00 am |
Break |
|
10:15 am |
Tax Consequences
of Exchanging.
●
Computing taxable gain: Boot and boot offset
rules
● Selling
expenses: Deductible or not
●
Re-financing: Before and after exchanging
Deferred Exchanges
●
Identification and receipt provisions: 45 day
rule, disaster extensions
● Safe
harbors from constructive receipt: Qualified
intermediaries, trusts and escrows
●
Protecting the exchange funds from loss |
|
11:45 pm |
Lunch
(provided) |
|
1:00 pm |
Reverse and
Improvement Exchanges
● Safe harbor
reverse exchanges
● Improvement
exchanges
● Combination
reverse and deferred exchanges
Seller
Financing, Partnerships and Tenancies in Common,
Foreclosures
● How
to deal with installment notes in an exchange
●
Partnership dissolutions and formations
● What
is and is not a tenancy in common for 1031
● Structuring
an exchange from a foreclosure |
|
2:30 pm |
Adjourn |
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CONFERENCE
INTENSIVES
Wednesday,
October 21, 2009 |
|
3:00 pm - 5:00 pm |
Casualties and
Condemnations Under Section 1033
Mary Foster and
David Shechtman
Section 1033 has
taken on increased importance recently in light
of hurricanes and other natural disasters, and
is likely to become significant as private land
is taken for proposed infrastructure projects.
This session will explore the workings of the
tax deferral opportunities available under this
provision. |
|
3:00 pm - 5:00 pm |
Private REITs: What Are They and Why Are They
Hot?
Lou Weller and
Joyce Welch
REITs
offer investors a way to buy positions in
diversified pools of real estate assets. While
the best-known REITs are publicly traded, there
has recently been a boom in formation of REITs
which are registered with the SEC but sold to a
limited number of investors and not listed on a
stock exchange. One use of these vehicles
has been to facilitate 1031 exchanges into a
diversified group of assets. This session
will explore the uses of "private" REITs, their
structures and their role in the current real
estate marketplace. |
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ADVANCED
Program Day
One
Thursday,
October 22, 2009 |
|
8:00 am |
Registration &
Continental Breakfast. |
|
9:00 am |
Program
Overview. Lou Weller |
|
9:15 am |
Recent
Developments: Overview of Cases, Legislation and
Rulings in the past year.
Mary Foster |
|
9:45 am |
Handling Exchanges Involving Partnerships:
Renewed IRS interest in partnership exchanges
merits revisiting common and not-so-common
issues associated with these transactions.
Richard Lipton, Bob
Schachat, Lou Weller |
|
10:45 am |
Break. |
|
11:00 am |
Intellectual Property and other Intangibles
in Light of New IRS Approach: IRS has
reversed position on availability of Section
1031 for many types of intangible property.
What opportunities now exist for these
transactions?
Adam Handler, Howard Levine, Dave Shechtman |
|
12:00 pm |
Luncheon
with speakers |
|
2:00 pm |
Credit Market
Fallout: The 2008-09 freeze in credit
markets created many issues for buyers and
sellers of assets, including those wishing to do
like-kind exchanges. Foreclosures and
workouts have become common and sales often can
only be structured using non-equity sources such
as carry-back financing and contingent debt.
What are the consequences for exchanges of these
and other credit-related issues? Richard
Lipton, Howard Levine, Bob Schachat |
|
3:00 pm |
Break. |
|
3:15 pm |
Issues Arising
From QI Failures: QI failures made news in
2008 and 2009. What tax consequences arise
and what lessons can be learned from these
events? Do structures designed to protect
exchangors against loss of funds and failure of
their exchange really work?.
Mary Foster, Dave
Shechtman, Lou Weller |
|
4:00 pm |
The View from
Washington. Donna Crisalli
and all speakers |
|
5:00 pm |
Adjourn |
|
5:30 pm |
Reception for
All Attendees. |
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ADVANCED
Program Day
Two
Friday,
October 23, 2009 |
|
7:30
am |
Continental
Breakfast. |
| |
TRACK A |
TRACK B |
|
8:30 am |
Who is the Exchangor?
Who must
particpate in exchanges involving spouses,
disregarded entities, corporate subsidiaries and
the like.
Mary Foster, Dick
Lipton |
REIT Issues:
REITs frequently use exchanges and sometimes are
used as an "exit vehicle" for exchangors. How
and why do the special rules governing REITs
affect their utilization of Section 1031?
Adam Handler, Bob Schachat |
|
9:20 am |
Break |
Break |
|
9:30 am |
Deferred and
Related Party Exchange Issues: The rules
relating to related parties and many issues in
deferred exchanges continue to puzzle exchangors
in many situations. What is the latest
thinking about possible answers to open
questions?
Adam Handler, Howard Levine |
TIC Update:
Current issues for buyers and sellers of TIC
interests in light of TIC sponsor meltdowns and
a deteriorating market. Has the TIC
marketplace remained viable?
Dick Lipton, Lou Weller |
|
10:20 am |
Break |
Break |
|
10:30 am |
What is
"Like-Kind?": Determining when properties
are "like-kind" is sometimes surprisingly
difficult, even for tangible property.
We'll discuss the issue of when fixtures are
considered real estate, how to deal with
personal property outside the "Like Class" safe
harbor and other related issues.
Howard Levine, Lou Weller |
Oil & Gas and
Other Mineral Interest Exchanges: Special
issues associated with exchanges of mineral
interests.
Dave Shechtman, Joyce
Welch |
|
11:20 am |
Break |
Break |
|
11:30 am |
8824 Workshop:
A hands on discussion of what information
must, may, should be included in Form 8824.
Marty Verdick,
Joyce Welch |
Non Safe Harbor
Reverse Exchanges: Practical tips for
handling construction and other non-safe harbor
reverse transactions in light of current
guidance.
Mary Foster, Dave
Shechtman |
|
12:20 pm |
Lunch on Your
Own. |
|
2:00
pm |
Roundtables with
speakers to discuss hypothetical exchange
transactions: Speakers will divide into
groups for discussion of hypothetical
transactions and transactions submitted by
attendees |
|
3:15
pm |
Break |
|
3:30
pm |
General Session:
Questions and Wrap Up on all Topics.
All Speakers |
|
4:30 pm |
Adjourn |
The entire conference may receive
up to 21.5 CPE credit hours.
Click here for more details
* Please note
that the above schedules are subject to change without
notice
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