To give CPAs and other tax professionals the technical skills to service real estate partnerships. You will gain a deeper understanding of the business of real estate formation, finance and operation. You'll be able to identify relevant tax issues and plan aggressively for your company or clients.
DETAILED LEARNING OBJECTIVES
• Distinguish the federal income tax characteristics of partnerships from entity-level taxation
• Recognize the flow-through taxation treatment generally applicable to partnerships
• Identify business entities generally subject to double taxation
• Identify entity structures commonly used to hold real estate
• Distinguish partnership-level tax elections from partner-level limitations
• Identify permissible methods of accounting for partnerships
• Determine when a partnership may use the cash method of accounting
• Identify the 2026 gross receipts threshold for using the cash method of accounting
• Recognize when an entity is treated as a tax shelter under the syndicate rules
• Identify the presumption period applicable to disguised sales of property
• Determine when liability relief resulting from a property contribution causes a partner to recognize gain
• Calculate gain resulting from the contribution of property subject to liabilities
• Determine when a restricted partnership capital interest received for services is included in income
• Identify the components of a partner’s initial outside basis
• Calculate the gain allocated to a contributing partner under Section 704(c)
• Calculate the post-contribution gain allocated to a noncontributing partner under Section 704(c)
• Distinguish a partner’s outside basis from the partnership’s inside basis
• Identify transactions and allocations that increase a partner’s outside basis
• Identify transactions and allocations that decrease a partner’s outside basis
• Recognize the constructive liquidation concept used to allocate recourse liabilities
• Identify when a partner bears the economic risk of loss for recourse debt
• Distinguish nonrecourse liabilities from recourse liabilities
• Identify circumstances in which a partner’s payment obligation may not be respected under the Section 752 regulations
• Determine how pre-contribution gain is treated when allocating nonrecourse liabilities
• Identify the criteria used to determine whether a contribution and distribution constitute a disguised sale
• Identify the substantial economic effect requirement governing partnership allocations
• Recognize the timing requirement associated with a deficit restoration obligation
• Identify items that increase a partner’s Section 704(b) book capital account
• Recognize the application of a qualified income offset
• Identify the first tier used to allocate partnership nonrecourse liabilities
• Recognize the standards governing the selection of a Section 704(c) allocation method
• Identify acceptable methods for making Section 704(c) allocations
• Explain the purpose of a Section 754 election following the transfer of a partnership interest
• Identify the steps used to calculate and allocate a Section 754 basis adjustment
• Recognize the filing requirements for making a Section 754 election
• Explain the EBITDA-based adjusted taxable income calculation used under Section 163(j)
• Determine when advance rent is included in taxable income
• Apply the tax recognition rules governing advance rental payments
• Identify the MACRS recovery period for nonresidential real property
• Identify the MACRS recovery period for residential rental property
• Identify the rental payment threshold applicable under Section 467
• Determine when a tenant security deposit must be included in a landlord’s taxable income
• Identify the holding period required for long-term capital gain treatment under Section 1061
• Apply the identification and completion deadlines governing deferred Section 1031 exchanges
• Identify parties that may serve as qualified intermediaries in Section 1031 exchanges
• Identify the replacement period for condemned business or investment real property under Section 1033
• Recognize circumstances that may result in a real estate foreclosure
• Distinguish a recourse mortgage from a nonrecourse mortgage
• Determine whether a taxpayer is insolvent by comparing liabilities with the fair market value of assets
• Identify the qualified real property business indebtedness exclusion from cancellation of debt income
• Recognize the tax disadvantages of holding real estate through a C corporation
• Explain the OBBBA treatment of bonus depreciation for eligible property acquired after January 19, 2025
• Identify the depreciation consequences of electing out of the Section 163(j) business interest limitation
• Identify the capital account requirement under the substantial economic effect safe harbor
• Calculate gain and potential cancellation of debt income when recourse real estate debt is discharged through foreclosure
