Partnership Exchanges: Structuring “Drop and Swap” and “Mixing Bowl” Transactions – WEBINAR
Partner, Mark Wilensky is presenting with Maher Haddad, Attorney, Baker & McKenzie, on Minimizing the Risk of an Unfavorable Audit Outcome.
This CLE/CPE webinar will provide tax advisers with knowledge and tools to advise partnership clients looking to convert to a tenancy-in-common form of ownership of real estate in contemplation of a future sale of property or to create a master limited liability company for various commonly-owned real estate entities for the purpose of allowing partners to go their separate ways. The “drop and swap” technique can be implemented to validate an exchange by former partners of undivided interests in real estate previously owned in partnership form. This process also comes with substantial complexities and risks. The structure must comply with rigid IRS 1031 rules for tenancies in common. Counsel must also contend with the absence of specific IRS revenue rulings addressing the ability to defer tax in an exchange using the drop and swap structure.