Partnership Exchanges Under Current Tax Law: Structuring "Drop and Swap" and "Mixing Bowl" Transactions
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide tax advisers with knowledge and tools to advise partnership clients converting to a tenancy-in-common form of real estate ownership. Tax advisers may recommend such a conversion in contemplating a future sale of property or creating a master limited liability company for various commonly owned real estate entities to allow partners to go their separate ways.
Outline
- Overview of Section 1031 partnership asset exchanges
- The use of Section 1031 under current tax law
- Drop and swap transaction
- Mixing bowl transaction
Benefits
The panel will review these and other priority issues:
- What are the requirements of IRC Section 1031 on partnership asset exchanges?
- How does tax reform impact the use of Section 1031 for certain assets?
- How must you implement the drop and swap transaction to maximize 1031 treatment on the property exchanged?
- How can the mixing bowl technique allow partners to separate their real estate holdings in commonly owned entities without triggering immediate tax?
Faculty
Professor Bradley T. (Brad) Borden
Professor of Law
Brooklyn Law School
Professor Borden’s research, scholarship, and teaching focus on taxation of real property transactions and... | Read More
Professor Borden’s research, scholarship, and teaching focus on taxation of real property transactions and flow-through entities (including tax partnerships, REITs, and REMICs). He teaches Federal Income Taxation, Partnership Taxation, Taxation of Real Estate Transactions, and Unincorporated Business Organizations, and he is affiliated with the Dennis J. Block Center for the Study of International Business Law. His work on flow-through and transactional tax theory appears in articles published in law reviews including Baylor Law Review, University of Cincinnati Law Review, Florida Law Review, Georgia Law Review, Houston Law Review, Iowa Law Review, Tax Lawyer, and Virginia Tax Review, among others. His articles also frequently appear in leading national tax journals including Journal of Taxation, Journal of Taxation of Investments, Real Estate Taxation, and Tax Notes.
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Marie C. Flavin
Senior Vice President/Northeast Regional Manager
Investment Property Exchange Services
Ms. Flavin is a member of the New York and Connecticut Bars, and has been practicing real estate law since 1992. She... | Read More
Ms. Flavin is a member of the New York and Connecticut Bars, and has been practicing real estate law since 1992. She has been specializing in 1031 exchanges with IPX since 1999. In her position as Northeast Regional Manager of Investment Property Exchange Services, Ms. Flavin frequently lectures and writes articles on IRC § 1031 tax deferred exchanges. She teaches Continuing Legal Education and Continuing Professional Education to Attorneys and CPA’s. Ms. Flavin 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 in 1992.
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