UPREITs: fad or fixture?
Article Abstract:
A recent real estate financing device, the umbrella partnership real estate investment trust (UPREIT), has become very popular because it allows partners to defer gain recognition while being eligible for public financing. UPREITs avoid taxation on property transferred to the trust because of the partnership characteristics but such transfers may be treated as deemed distributions if they are in excess of the original partners' basis. Similarly, the payment of nonrecourse debt could reduce the minimum gain and property may have a fair market value in excess of the transferor's adjusted basis.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1993
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Restrictive proposed regulations on publicly traded partnerships could cause any partnership to be taxed as a corporation
Article Abstract:
The proposed IRS regulations released under IRC section 7704(b) in May 1995 would destroy the planning certainty for partnerships that IRS Notice 88-75 had provided. The proposed regulations would dismantle the percentage-based safe harbors for partnerships and potentially subject all partnerships to corporate taxation as publicly traded partnerships (PTPs). The limited qualified redemption and qualified matching service exemptions from PTP taxation under the proposed regulations do not provide any certainty. The lack of certainty will increase compliance costs and harm investment markets.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1995
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IRS addresses tax treatment of partnership distributions of a partner's debt or stock
Article Abstract:
IRS revenue ruling 93-7 and proposed IRC section 337(d) regulations define the taxation of partnership distributions of a partner's debt or stock and gain or loss recognition and cancellation of debt income applicability. The ruling and regulations create situations under which cash distributions would be treated differently than debt distributions and debt or stock could be treated as redeemed by the partner even if it never is. Therefore, the IRS has created questionable treatments that need further modification.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1993
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