Recent Speeches
- Partnership Book/Tax Disparities: How to Recognize, Create and Exploit Them, 2022 Oregon Tax Insitute (Portland, OR: May 2022)
- Choice of Entity After the TCJA of 2017, 2018 AICPA
National Real Estate & Constructions Conference (Las Vegas, NV: December 2018).
- Intermediate Partnership Taxation, 2018 AICPA National Real Estate & Construction Conference (Las Vegas, NV: December 2018).
- Allocation of Partnership Liabilities Under Section 752,
PLI Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances (Chicago, IL, New York, NY, and San Francisco, CA: May - June 2018).
- Exit Strategies for Partners with Deficit Capital Accounts, 2017 AICPA National Real Estate & Construction Conference (Las Vegas, NV: December 2017).
- Partnership Allocations, Distributions, and the Distribution Antiabuse Rules, 2017 AICPA National Real Estate & Construction Conference (Las Vegas, NV: December 2017).
- Wherefore Section 736?, 70th Annual University of Chicago Federal Tax Conference (Chicago, IL: November 2017) (panel presenter).
- Tax Reform, Harvard Law School Bicentennial Celebration (Cambridge, MA: October 2017) (panel participant).
- Allocation of Partnership Liabilities Under Section 752, PLI Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances (Chicago, IL, New York, NY, and San Francisco, CA: May - June 2017).
- The New Partnership Audit Rules, USD School of Law - RJS LAW Tax Controversy Institute (San Diego, CA: December 2016) (co-presenter).
- Partnership Exit Strategies, 2016 AICPA National Real Estate
& Construction Conference (Las Vegas, NV: November 2016).
- Partnership Update, 2016 AICPA National Real Estate &
Construction Conference (Las Vegas, NV: November 2016).
- A Comparative Look at Tax Courts: The US and Mexico, 2016 University of San Diego School of Law - Procopio International Tax Institute (San Diego, CA: November 2016).
- Exchanges by Partnerships: Exploring the Prickly Relationship Between Section 1031 and Subchapter K, 21st Annual Jeremiah Long Memorial Conference on Like-Kind Exchanges Under IRC §1031 (San Diego, CA: October 2016) (with Lou Weller).
- Partnership Update, California State Bar Tax Section Annual Meeting (San Diego, CA: October 2016).
- Leveraged Partnership Distributions, 2016 Oregon Tax Institute (Portland, OR: June 2016) (co-presenter).
- Advanced Basis Issues: Impact of Liabilities, 2016 PLI Tax Planning for Domestic and Foreign Partnerships, LLCs, Joint Ventures and Other Strategic
Alliances (Chicago, IL; New York, NY; San Francisco, CA: April, May, June 2016).
- Leveraged Partnership Distributions, 2015 USC Annual Tax Institute (Los Angeles, CA: January 2016) (co-presenter).
- Advanced Partnership Taxation on Disguised Sales and Exit Strategies, CPAmerica 2015 Tax Forum (Santa Rosa, CA: July 2015).
- Intermediate Partnership Taxation On 704(c) Allocations, 752 Debt Allocations, Disguised Sales and Mixing Bowl Transactions, and Exit Strategies, CPAmerica Webinar Series (May, June 2015).
- Advanced Section 752 Planning, PLI Tax Planning for Domestic and
Foreign Partnerships, LLCs, Joint Ventures and Other Strategic Alliances 2014
(Chicago, IL; New York, NY: May 2014).
- Partnership Distributions, Harvard Law School Tax Policy Seminar (Cambridge, MA: March 2014).
- Partnership Inequalities, 66th Annual University of
Chicago Federal Tax Conference (Chicago, IL: November 2013) (panel presenter).
- Partnership Debt Issues, 2013 AICPA National Real
Estate Conference (Las Vegas, NV: November 2013).
- Buying and Selling a Partnership Interest: A Checklist for the Tax
Advisor, 2013 AICPA National Real Estate Conference
(Las Vegas, NV: November 2013).
- Tax Planning Workshop: “Drop & Swap” and “Mixing Bowl” Techniques,
2013 ABA Tax Section Fall Meeting (San Francisco, CA:
September 2013) (panel
participant).
- Tax Credit Planning After Historic Boardwalk and
Anticipated IRS Guidance, 2013 ABA Tax Section Fall Meeting
(San Francisco, CA: September 2013) (with Steven Berman).
- Partnership Noncompensatory Options, BNA/Bloomberg Tax Advisory Board Meeting (New York, NY: June 2013) (with R. Crnkovich).
- Now You See it, Now You Don't: Exiting a Partnership and Making Gain Disappear, 2013 Northwestern Graduate Tax Seminar (Chicago, IL: February 2013).
- Is Your Partner Under the Boardwalk?, 2013 ABA Tax Section Mid-Year Meeting (Orlando, FL: January 2013) (panel moderator).
- Credit Where Credit Is Due: Who is a Partner After Historic Boardwalk, Bloomberg/BNA Tax Advisory Board Meeting (New York, NY: December 2012).
- When Partners Go Their Separate Ways: A Case Study, CPAmerica 2012 Tax Forum (Nashville, TN: November 2012).
- Partnership Hot Topics, 2012 AICPA National Real Estate Conference (Las Vegas, NV: November 2012).
- Regarding Disregarded Entities, 2012 AICPA National Real Estate Conference (Las Vegas, NV: November 2012).
- Taxation of the Cost of a Professional Education, USD Tax Law Speakers Series (San Diego, CA: October 2012).
- Extracting Cash from a Partnership in Connection with a Property Contribution: Tax-free or Just a Brilliant Disguise?,
47th Annual Southern Federal Tax Institute (Atlanta, GA: October 2012) (with M. Mollerus).
- To Book Up or Not to Book Up: That Is the Question, 2011
ABA Tax Section May Meeting (Washington, DC: May 2011) (panel participant).
- Partnership Taxation and Restructuring, 2011 AICPA Annual National Real
Estate Conference (Scottsdale, AZ: November 2011).
- Partnership Taxation for Fun and Profit, 2011 AICPA Annual Real Estate
Conference (Scottsdale, AZ: November 2011).
- Planning for Debt Discharge Income and Section 108 Relief: Part 2,
ABA Teleconference (December 2010) (with F. Witt).
- Partnership Financial Restructuring, 64th Annual
Federal Tax Clinic (Tuscaloosa, AL: November 2010).
- Getting Into and Out of a Partnership: Carried Interests, Economic
Substance and Debt Issues, 2010 AICPA National Real Estate
Conference (Las Vegas, NV: November 2010).
- Two Hours of Partnership Taxation, 2010 AICPA National
Real Estate Conference (Las Vegas, NV: November 2010).
- Getting Into and Out of a Partnership: Carried Interests, Economic
Substance, and Debt Issues, CPAmerica 2010 Tax Forum
(Charleston, SC: November 2010).
- Planning for Debt Discharge Income and Section 108 Relief,
ABA Teleconference (September 2010) (panel participant).
- Don't Get Carried Away by Carried Interests, ABA Tax Section Fall
Meeting (Toronto, ON: September 2010) (panel participant).
- Did Codification of Economic Substance Repeal the Partnership Anti-Abuse
Rule, BNA Tax Advisory Board Meeting (New York, NY: June
2010).
- Tax Efficient Ways of Exiting a Partnership, 2010 GSCPA
Real Estate Conference (Atlanta, GA: June 2010).
- Partnership Cancellation of Indebtedness and Related Issues,
2009 AICPA National Real Estate Conference (New Orleans,
LA: November 2009).
- Intermediate Partnership Taxation, 2009 AICPA National
Real Estate Conference (New Orleans, LA: November 2009).
- Choice of Entity: Disregarded Entities, Partnerships and S
Corporations, CPAmerica 2009 Tax Forum (San Francisco,
CA: November 2009).
- I Need Money: Tax Efficient Ways of Exiting a Partnership, 44th
Annual Southern Federal Tax Institute (Atlanta, GA: October
2009).
- Now You See It, Now You Don't: Exiting a Partnership and Making Gain
Disappear, BNA Tax Advisory Board Meeting (New York, NY:
December 2008).
- Getting Into and Out of a Partnership, 2008 Great Plains
Tax Institute (Omaha, NE: December 2008).
- Partnership Tax Issues, 2008 AICPA National Real Estate
Conference (Phoenix, AZ: November 2008).
- Partnership and Fund Tax Issues, 2008 AICPA National
Real Estate Conference (Phoenix, AZ: November 2008).
- Capital Gains Planning, 2008 National AICPA Real Estate
Conference (Phoenix, AZ: November 2008) (with L. Weller).
- Advanced Partnership Taxation, 2008 CPAmerica
International 2008 Tax Forum (Palm Coast, Florida: November 2008).
- Partnership Mixing Bowls: Problems and Solutions, Atlanta
Tax Forum (Atlanta, GA: September 2008).
-
Getting Into and Out of a Real Estate Partnership, 2008 Super
Conference (Nashville, TN: August 2008).
-
The Fight Over Carried Interests — Legislative Proposals and Pitfalls,
24th Annual Texas Federal Tax Institute (San Antonio, TX: June
2008) (panel participant).
-
Disguised Sales, Mixing-Bowls and Synthetic Installment Sales,
2008 GSCPA Real Estate Conference (Atlanta, GA: May 2008).
-
Order in the Court: The Importance of Timing in Partnership Transactions,
ABA Tax Section May Meeting (Washington, DC: May 2008) (panel
participant).
- Taxing Carried Interests and Tax Reform, Loyola University
Chicago Law Journal Conference on Tax Law in a Liberal Democracy
(Chicago, IL: March 2008).
- Partnership Carried Interests: The Past Is Prologue, Tax
Management Luncheon (Washington, DC: January 2008).
- Update on Partnership Carried Interests, Tax Policy
Advisory Committee to the Real Estate Roundtable (Washington, DC:
January 2008).
- The Past is Prologue: Carried Interests, BNA Tax Advisory Board Meeting (New York, NY: December 2007).
- Hot Topics in Partnership Taxation, 2007 AICPA National Real Estate Conference (Las Vegas, NV: November 2007).
- Basic Partnership Taxation, 2007 AICPA National Real Estate Conference
(Las Vegas, NV: November 2007).
- Creative Tax Planning for Real Estate Transactions, ALI-ABA Advanced Course of Study (Atlanta, CA: October 2007) (panel participant).
- Partnership Carried Interests: A Look Forward, Tax Policy Advisory Committee to the Real Estate Roundtable (Washington, DC: October 2007).
- Partnership Carried Interests, ABA Tax Section Fall Meeting (Vancouver, BC: September 2007) (panel moderator).
- Update on Carried Interests, Atlanta Bar Association: Real Estate Section (Atlanta, GA: August 2007).
- Partnership Carried Interests, Panel for the Senate Staff of the Banking and Finance Committees Sponsored by the Managed
Funds Association and the U.S. Chamber of Commerce (Washington, DC: July 2007).
- Partnership Allocation of Real Estate Tax Credits, BNA Tax Advisory Board Meeting (New York, NY: June 2007).
- Partnership Carried Interests, Real Estate Roundtable Tax Policy
Advisory Committee Meeting (Washington, DC: June 2007).
- Tips and Traps in Forming a New Partnership, 2007 GSCPA Real Estate Conference
(Atlanta, GA: May 2007).
- Section 751(b) Hot Assets -- The ABA Proposals, 2007 ABA Tax
Section May Meeting (Washington, DC: May 2007) (panel moderator).
- Series LLCs, The Samuel and Ronnie Heyman Center on Corporate
Governance at the Benjamin N. Cardozo School of Law (New York, NY: April
2007) (panel participant).
- Partnership Update, 2006 AICPA Annual Real Estate Conference
(Phoenix, AZ: November 2006).
- Getting In and Getting Out of a Partnership, 2006 AICPA Annual
Real Estate Conference (Phoenix, AZ: November 2006).
- Tax Aspects of Real Estate, ABA Tax Section CLE
on the Road (Atlanta, GA: June 2006) (with T. Cuff and S. Kalus).
- Suggestions for Modernizing Section 751(b), BNA
Tax Advisory Board Meeting (New York: June 2006).
- Cash and Carried Interest, Southeast Tax Institute 2006 (Atlanta, GA: May 2006).
- Creative Use of Partnership Debt, 25th (2006) J. Nelson Young Tax Institute (Chapel Hill, NC: April 2006).
- Partnership Disguised Sales, 2005 AICPA
National Real Estate Conference (Las Vegas, NV: November 2005).
- Partnership Taxation, 2005 AICPA National Real Estate Conference
(Las Vegas, NV: November 2005).
- The Section 734(b) Basis Adjustment Needs Repair, Northwestern Law
School Graduate Tax Colloquium (Chicago, IL: January 2005).
- The Truth About Partnership Debt. Guaranteed, BNA Tax Advisory
Board Meeting (New York, NY: December 2004).
- Tax Aspects of Real Estate Investing Through a Partnership, 2004 AICPA
National Real Estate Conference (Indian Wells, CA: November 2004).
- Deduction for Construction Activities: New Section 199, 2004 AICPA
National Real Estate Conference (Indian Wells, CA: November 2004).
- Tax Issues Arising From the Admission of a Partner to a Partnership,
39th
Annual Southern Federal Tax Institute (Atlanta, GA: September 2004).
- Consolidated Group Joint Ventures, Including One-Party Limited Liability
Companies, 2004 ALI-ABA Consolidated Tax Return Regulations (Washington, DC:
September 2004) (with L. Zarlinga and W. Wasserman).
- Income Tax Consequences of Dissolving a Family Limited Partnership,
2004
Fiduciary Law Institute (St. Simons, GA: July 2004).
- Tax-Efficient Ways of Extracting Value From a Real Estate Partnership,
2004 GSCPA Real Estate Conference
(Atlanta, GA: June 2004).
- Partnership Noncompensatory Options,
Eighth Annual Federal
Real Estate Tax Conference (Washington, DC: December
2003).
- Tax Efficient Ways of Extracting Cash From a Real Estate Partnership,
2003 AICPA National Real Estate Conference (New Orleans, LA: November
2003).
- Partnership Taxation, 2003 AICPA National Real Estate Conference
(New Orleans, LA: November 2003).
- Consolidated Group Joint Ventures, Including One-Party Limited Liability
Companies, 2003 ALI-ABA Consolidated Tax Return Regulations (Washington,
DC: October 2003) (with L. Zarlinga and W. Wasserman).
- Cash and Carried Interests: Protecting Both the Developer and the Investor
in a Real Estate Partnership, 2003 GSCPA Real Estate Conference
(Atlanta, GA: June 2003).
- Creative Use of Partnership Debt, Seventh Annual Federal
Real Estate Tax Conference (Washington, DC: December
2002).
- Partnership Taxation for the Real Estate Professional,
2002 AICPA National Real Estate Conference (Las Vegas, NV: November
2002).
- A Practical Guide to the Contribution of Appreciated
Property to Partnerships, Louisiana State Bar Tax
Section: Mardi Gras Meeting (New Orleans, LA: February 2002).
- Estate Planning Implications of the 2001 Act for Real Estate, 2002
ABA Tax Section—Real Estate Committee: Mid-Year Meeting (New Orleans,
LA:
January 2002).
- Bringing Fresh Money Into the Deal: Adding a New Cash
Investor to an Existing Partnership, Sixth Annual Federal
Real Estate Tax Conference (Washington, DC: December 2001).
- Adding a New Cash Partner to an Operating Partnership, 2001 AICPA National Real Estate Conference (Atlanta, GA:
November 2001).
- Intermediate Partnership Taxation, 2001 AICPA National
Real Estate Conference (Atlanta, GA: November 2001).
- Ethical Issues in Real Estate Transactions, ALI-ABA
Creative Tax Planning for Real Estate Transactions (San
Francisco, CA: October 2001).
- A Practical Guide to the Contribution of Appreciated
Property to Partnerships, Chattanooga Tax Practitioners
December Meeting (Chattanooga, TN: December 2000).
- Real-World Issues in Contributing Appreciated Property to a
Partnership, 2000 AICPA National Real Estate Conference
(Las Vegas, NV: November 2000).
- Partnership Deal Structures: Entering, Exiting, and the
Mixing Bowl, Federal Taxation of Real Estate Transactions
Symposium (Columbus, OH: November 2000).
- Forming a Real Estate Partnership: A Practical Look at the
Section 704(c) Options, Fifth Annual Federal Real Estate
Tax Conference (Washington, DC: November 2000).
- Partnership Mergers and Divisions, 59th NYU Institute
on Federal Taxation (New York, NY: November 2000)
- Pathological Partnership Debt, ALI-ABA Conference on
Creative Tax Planning for Real Estate (Boston, MA: September 2000).
- Partnership Mergers and Divisions, 16th Annual Texas
Federal Tax Institute (San Antonio, TX: June 2000).
- Something Simple: Joining and Exiting a Partnership, 37th Great Plains Federal Tax Institute (Lincoln, NE:
December 1999) (with Fred Witt).
- Issues and Strategies in Exiting Partnerships, Fourth
Annual Federal Real Estate Taxation (Bethesda, MD: November 1999).
- Partnership Tax Issues, 1999 AICPA National Real Estate
Conference (Orlando, FL: November 1999).
- Choice of Entity/Planning With Entities, Deloitte &
Touche Financial Consulting Services Annual Meeting
(Orlando, FL:
November 1999) (with M. Lux).
- The Effect of E-Commerce on the Real Estate Industry,
1999 Annual Deloitte-Touche Real Estate Conference
(Denver, CO:
September 1999).
- Doing the McCauslen Two-Step: Did the Government Get It
Right in Revenue Ruling 99-6?, 1999 ABA Tax Section—Real
Estate Committee: Annual Meeting (Atlanta, GA: June 1999).
- Issues and Pitfalls in Exiting Partnerships, 57th NYU
Institute on Federal Taxation (New York, NY and San Diego,
CA:
November 1998).
- Dispositions of Partnership Interests, 1998 ABA Tax
Section—Real Estate Committee: May Meeting
(Washington, DC:
May 1998).
- Distributions From Highly Leveraged Partnerships, 1997
ABA Tax Section—Real Estate Committee: Annual Meeting
(San Francisco, CA: August 1997).