Dr. Hughlene Burton,  Ph. D. , CPA, Associate Professor of Accounting, University of North Carolina

This session will explore any changes in the tax law regarding partners and partnerships as well as look at regulations, rulings and court cases that have been issued in the past year.

Brian J. O’Connor, Esq., Partner, Venable

Steven R. Schneider, Esq., Partner, Stroock & Stroock & Lavan

This session covers creative real estate deal structures related to transactions involving both the entry and exit from joint ventures, recapitalizations, revaluations, preserving negative capital accounts, debt and equity planning, REIT planning, and other tax-focused transactional planning.

Ryan P. McCormick, Esq., Senior Vice President and Counsel, The Real Estate Roundtable

This session will review recent legislative developments related to real estate and partnership taxation and discuss the outlook for tax legislation in the year ahead.  Taking place just one day after the mid-term elections, the session will consider how the shifting political landscape in Washington, DC and around the country is likely to affect real estate and partnership tax policy.

Paul Wilner, CPA, Managing Partner, Grossberg Company, LLP

The presenter discusses the mechanics of Section 704(c) and reverse Section 704(c) allocations: the traditional method, ceiling limitation principles, traditional method with curative allocations, remedial allocation method, various operating rules in the Section 704(c) regulations, Section 704(c)(1)(C); anti-abuse provisions, mandatory adjustments, tax distribution considerations, and planning concepts.

Matt Eddleman, CFP, Tax Director, Frost Law

Norman Lencz – Moderator, Esq. Partner, Venable, LLP

Walter Calvert, Esq., Partner, and Chris Moran, Esq., Associate, Venable, LLP

A plethora of cases and rulings have come out over the past year with widely divergent facts, analysis, and outcomes regarding how gain from the sale of a partnership interest is sourced to and taxed by the states.

But the overall theme is not hard to find: states are looking ever more aggressively at how to tax nonresidents on gain from the sale of partnership interests when the partnership has any business activity in the state.

The result is an erosion of the state tax principle that nonresidents are taxed on income from intangible assets only by their state of residence.