Upreit Tax Issues

ALI-ABA Course Of Study Creative Tax Planning For Real Estate ...
Creative Tax Planning for Real Estate Transactions September 25 - 27, 2008 Chicago, Illinois Selected Tax Issues Relating to the Use of Partnerships in REIT Transactions By Peter J. Genz King & Spalding LLP Atlanta, UPREIT partnerships, ... Visit Document

HEALTH-CARE REITS COULD BE AN IMPORTANT SOURCE OF FINANCING ...
Selves of assets in a way that mitigates potential tax burdens. In an UPREIT structure, all properties are actually owned by a partnership of owned businesses that may be facing estate planning issues. When considering a partnership with a health-care REIT, measure the ability of the REIT to ... Get Content Here

Mapping The Labyrinth: Partnership Mergers And Divisions
Mapping the Labyrinth: Partnership Mergers and Divisions1 By: rules that determine the tax treatment of a merger transaction, it is necessary to determine which partnership (if any) continues and which partnership goes out of existence. ... Doc Retrieval

State And Local Tax - Mecseminars.com
State and Local Tax Across the country, dispute resolution, obtaining written guidance on tax issues, negotiating incentives, entering into voluntary disclosures, and providing advice on issues common to many states and public REITs, private REITs and non-REITs; UPREIT structures; ... View Document

UPREIT structure. Essentially, a newly formed corporation (“PubCo”) This tax basis step-up is allocated to PubCo’s share of the historic Miscellaneous Issues Related to Up-C Structure ... Fetch This Document

Workouts Involving UPREIT And DownREIT Properties: A Guide ...
Structures and tax protection provisions. The remarkable growth of U.S. public issues various tranches of debt, each of Workouts Involving UPREIT and DownREIT Properties: A Guide for REIT Executives. Borrower. ... Fetch This Document

Structuring REIT Roll-Ups, Conversions And Spin-Offs To ...
Structuring REIT Roll-Ups, Conversions and Spin-Offs to Maximize Asset Value Sponsor forms an UPREIT structure with a REIT parent and an operating partnership Tax Issues: Conversion of Existing C Corporation to REIT ... Return Doc

FASB And 1031 Exchange Impact On Single Tenant Industry
Michael is joined by Nancy Miller and Scott Lindstrom in Studio One to discuss the changes in FASB and 1031 exchanges and the affect those changes will have on the single tenant net lease industry. ... View Video

The Major issues Facing The Successful Introduction Of The UK ...
The major issues facing the successful introduction of the UK REIT Received: tjth May, tax returns from holding real estate indirectly with those obtained the US REIT market has developed the 'UPREIT' ... Access Doc

Real Estate Investment Trust - Wikipedia
A real estate investment trust (REIT) is a company that owns, to avoid incurring liability for U.S. Federal income tax, Retail REIT Taubman Centers Inc. launched the modern era of REITs in 1992 with its creation of the UPREIT. ... Read Article

A Publication Of Bryan Cave LLP Tax Advice And Controversy ...
Primary tax planning and structuring issues relating to the taxable gain under Code Sec. 752 that might arise in an UPREIT transaction. UPREITs in general Generally speaking, an UPREIT structure is created by first having the REIT form an “operating partnership.” ... Get Doc

Tax Law PDF - Riker.com
Personal tax planning Riker Danzig's tax law group has a strong business orientation and disposition of real estate holdings through tax-free exchanges or contributions to UPREIT has resulted in a variety of published opinions on such significant state tax issues as unitary ... Return Doc

Up-C IPO Tax Considerations - Morrison & Foerster
UP-C IPO Tax Considerations Thomas A. Humphreys Remmelt A. Reigersman . UPREIT Features instruments tax, but we try to guide you through the tax results when an issuer issues a negative interest bond. 6. ... Read Content

INCOME TAX ISSUES IN FORMING AND LIQUIDATING PARTNERSHIPS
1 INCOME TAX ISSUES IN FORMING AND LIQUIDATING PARTNERSHIPS Eric L. Green Convicer & Percy, LLP 41 Hebron Avenue Glastonbury, Connecticut 06033 ... Get Content Here

CATALOG - CPE Seminars
CATALOG . Course Outline below. Provider of Continuing Professional Education (CPE) to . C (UPREIT): Special Tax Considerations B. Depreciation Issues Leasing Property to a Tax-Exempt Entity Joint Ventures with Tax- Exempt Entities : ... Retrieve Full Source

Frequently Asked Questions About Real Estate Investment Trusts
FREQUENTLY ASKED QUESTIONS ABOUT REAL ESTATE INVESTMENT TRUSTS REIT Basics preferential tax treatment. It is a “pass‐through” entity What is an UPREIT? ... Access Full Source

Explanation Of The New Sunwest Business Structure
Explanation of the New Sunwest Business Structure Investors elect REIT or UpREIT (MLP) based on tax issues. > TICs electing to protect tax-deferral position go into MLP. > All others exchange existing claims or interests for securities and go into ... Retrieve Content

Proposed Treasury Regulations Modify Debt Allocation And ...
Allocation of liabilities, and other partnership tax issues. Although contributions of real estate to UPREIT and other partnerships are generally tax-free, complications arise when, as is usually the case, ... Retrieve Here

Office Of The Comptroller Of The Currency Federal Deposit ...
An UPREIT is “a tax-driven vehicle.” “An UPREIT provides a means of transferring Accounting Issues You asked how a financial institution would account for its preferred stock purchase -- as an investment or a loan. ... Access Document

Top State & Local Tax Developments & Issues Affecting The ...
Top State & Local Tax Developments & Issues Affecting the Real Estate Industry Steven Lawrence, CPA Joseph Flack, CPA Partners. • Income Tax Issues 15 • A “UPREIT” partnership strategy provides for tax‐free ... Fetch Doc

Reits And Upreits: Pushing The Corporate Law Envelope
Issues they present, to realize additional tax advantages not found in the basic REIT structure. Because of the UPREIT structure presents many inherent conflicts between shareholders and fiduciaries that a regular corporation does not. ... Get Doc

CURRENT TAX ISSUES AFFECTING REAL ESTATE By Howard J. Levine ...
Current Tax Issues Affecting Real Estate Howard J. Levine Joseph Lipari Proposed Regulations under Sections 707 and 752 On January 30, 2014, An UPREIT structure is onewherein a real estate investment trust ("REIT") ... Document Retrieval