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Jeremiah Long Memorial
National Conference
on Like-Kind Exchanges
Under Section 1031 I.R.C.
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2011
Schedule
Wednesday,
October 26
Overview
Wednesday, October 26
Conference
Intensives
Thursday & Friday,
October 27 & 28
Advanced
2 Day
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OVERVIEW
Wednesday,
October 26, 2011
Presented
by Mary B. Foster and Martin E. Verdick
CPE Credit
Hours - 5
Texas MCLE
Credit Hours - 4.25
CES®
Continuing Education Credits - 4.5 |
|
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 |
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11:45 am |
Lunch
(provided) |
|
1:00 pm |
Reverse and
Improvement Exchanges
● Safe harbor
reverse exchanges
● Improvement
exchanges
● Combination
reverse and deferred exchanges
Seller
Financing, Partnerships, Tenancies in Common and
Foreclosures
● How
to deal with installment notes in an exchange
●
Partnership dissolutions and formations
● What
is and is not a tenancy in common for Section 1031
● Structuring
an exchange from a foreclosure |
|
2:30 pm |
Adjourn |
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CONFERENCE
INTENSIVES
Wednesday,
October 26, 2011
CPE Credit
Hours - 2.5
Texas MCLE
Credit Hours - 2
CES®
Continuing Education Credits - 2.25 |
|
3:00 pm - 5:05 pm |
Primer on
Partnership Exchanges
Joyce L. Welch
and
Louis S. Weller
A review of tax
issues relating to exchanges by partnership for
those who don't consider themselves Subchapter K
specialists. Will include current state of
tax authority responses to basic "drop & swap"
and "swap & drop" transactions. |
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3:00 pm - 5:05 pm |
Tax Accounting Aspects of Reverse and
Construction Exchanges
Mary B. Foster and
Martin E. Verdick
An in depth
analysis of the tax accounting and reporting
consequences related to "safe-harbor" exchanges
under Rev. Proc 2000-37, including financing,
operations and property transfers. Will
cover combination reverse/forward exchanges and
tax filing requirements for an EAT, as well as
state tax issues faced by EATs. |
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ADVANCED
PROGRAM DAY ONE
Thursday,
October 27, 2011
Total CPE
Credit Hours for Advanced Program - 13
(UPDATE: 10.5
General and NOW 2.5 Ethics)
Total Texas
MCLE Credit Hours for Advanced Program - 11
(10 General
and 1 Ethics)
Total CES® Continuing Education Credits for
Advanced Program - 11.5
(UPDATE: 9 General and NOW 2.5 Ethics) |
|
8:00 am |
Registration &
Continental Breakfast |
|
9:00 am |
Program
Overview: Louis S. Weller |
|
9:10 am |
Recent
Developments: Overview of Cases, Legislation and
Rulings in the past year.
Mary B. Foster |
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9:45 am |
Oil & Gas &
Minerals (aka Lions & Tigers & Bears): Current
Issues: As these exchanges become more
important and widespread, what issues keep
planners and clients up at night? Adam
M. Handler,
David Shechtman, Louis S. Weller |
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10:45 am |
Break |
|
11:00 am |
Morphing
Entities: Exchanges in the Context of
Corporate and Partnership Restructurings:
Examination of current approaches to exchanges
when entities are changing composition before,
during and after the transaction.
Terence F. Cuff, Howard
J. Levine, Robert
D. Schachat |
|
12:00 pm |
Luncheon
with
Faculty: Special
Speaker - Eugenio J. Alemán, Director and Senior
Economist at Wells Fargo Securities, LLC |
|
2:00 pm |
Related Party
Conundra: Update on planning for exchanges
involving related parties including sequential
transactions and scope of other exceptions to
1031(f)(4).
Mary B. Foster, Adam M.
Handler, Joyce L. Welch |
|
3:00 pm |
Break |
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3:10 pm |
1031 In a
Broader Context: Effect of Anti-Abuse
Legislation: What is the effect of newly
enacted preparer penalties, economic substance
codification and other anti-abuse efforts on use
of Section 1031 as a planning tool for taxpayers
and advisors? Charles
H. Egerton, Robert D. Schachat, David Shechtman
***This session qualifies
for 1 hour Ethic Credit for CPE and CES |
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4:00 pm |
The View from
Washington. Donna Crisalli,
Special Counsel to the Associate Chief Counsel
(IT&A) - IRS Representative,
Louis S. Weller as moderator, and all speakers |
|
5:00 pm |
Adjourn |
|
5:30 pm |
Reception for All Attendees |
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ADVANCED
PROGRAM
DAY TWO
Friday,
October 28, 2011 |
|
7:30
am |
Continental
Breakfast |
| |
TRACK A |
TRACK B |
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8:30 am |
Green Exchanges:
Exchanges involving
alternative energy and environmentally favored
assets such as emissions credits.
Mary B. Foster,
Louis S. Weller |
Accounting
Issues in Simultaneous and Deferred Exchanges:
Practical tips for reporting the consequences of
exchanges on tax returns and financial
statements.
Martin E.
Verdick, Joyce L. Welch |
|
9:45 am |
Break |
Break |
|
10:00 am |
Estate Planning
Uses of Exchanges: Applications of Section
1031 for and in the context of estate planning
Charles H. Egerton,
David Shechtman |
Practical Issues
in Structuring Reverse Exchanges:
Case study examination of documentation and
transaction issues created by recent reverse
exchange transactions.
Terence F. Cuff,
Adam M. Handler |
|
11:15 am |
Break |
Break |
|
11:30 am |
Contract
Documentation Issues in Standard and
Not-so-Standard Exchanges: Review of issues
created by sample exchange documentation and
suggested solutions.
David Shechtman,
Derrick M. Tharpe |
Mechanics of
Doing Exchanges Involving Distressed Debt:
Step by step analysis of how to exchange out of
and acquire property subject to debt exceeding
value.
Howard J.
Levine, Louis S. Weller |
|
12:20 pm |
Lunch on Your
Own |
|
2:00
pm |
Ethical Issues
for QIs and Advisors in Like-Kind Exchanges:
Terence F. Cuff, Charles
H. Egerton, Mary B. Foster, David Shechtman,
Derrick M. Tharpe
***This session qualifies
for 1.5 hours Ethics Credits for CPE and CES and
1 hour Ethic Credit for MCLE |
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3:15
pm |
Break |
|
3:30
pm |
General Session:
Questions and Wrap Up on all Topics.
All
Faculty |
|
4:30 pm |
Adjourn |
The entire conference may receive
up to 20.5 CPE
credit hours (this
includes one Intensive session, the Overview and Ethics),
Texas MCLE Credit Hours
- up to 17.25
for entire conference (this includes one Intensive
session, the Overview and Ethics)
CES®
Continuing Education Credits - up to
18.25 for entire conference (this
includes one Intensive session, the Overview and Ethics)
Click here for
more details.
* Please note
that the above schedules are subject to change without
notice
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