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About the Teleseminar
This program will provide you with a guide to sophisticated like-kind exchange planning in a market where prices have stabilized and are rising again. The program will discuss planning problems and drafting traps with forward and reverse exchanges, including with related parties. It will also cover techniques for minimizing the adverse effect of the receipt of “boot” in and the use of single-member LLCs and Family Limited Partnerships to increase the attractiveness of exchanges. Alternatives to like-kind exchanges, including mixing bowl transactions and leveraged acquisitions, will also be covered. This program will provide you with a framework for understanding advanced like-kind exchange planning formats, hidden planning and drafting traps and effective alternatives when like-kind exchanges are not appropriate.
Day 1 – May 2, 2013:
- Framework of advanced like-kind exchanges techniques and alternatives
- Use of trusts, single-member LLCs, and Family Limited Partnerships
- Simultaneous exchanges – the problematic use of intermediaries and key drafting traps
- Deferred exchanges – disqualified parties and safe harbors
- Techniques to solve the problem of “boot” in a transaction, including special allocations, installment sales, cross purchases and redemptions
About the Speakers
Brian J. O'Connor is a partner in the Baltimore office of Venable, LLP, where he is co-chair of the firm’s tax and wealth planning group. He provides sophisticated tax and business advice to closely-held and publicly-traded businesses and their owners. Before joining Venable, Mr. O’Connor was an attorney-advisor in the Office of the Chief Counsel of the IRS, where he worked on high profile legislative projects, regulations and other published guidance relating to pass through entities. Mr. O’Connor received his J.D., magna cum laude, from Washington and Lee University School of Law and his LL.M. in tax law, with distinction, from Georgetown University Law Center.
Norman Lencz is a partner in the Baltimore, Maryland office of Venable, LLP, where his practice focuses on a broad range of federal, state, local and international tax matters. He advises clients on tax issues relating to corporations, partnerships, LLCs, joint ventures and real estate transactions. He also has extensive experience with compensation planning in closely held businesses. Mr. Lencz earned his B.S. from the University of Maryland and his J.D. from Columbia University School of Law.
Mandatory MCLE Credit Hours
This seminar qualifies for 1.0 MCLE Credit Hour, including up to 1.0 Taxation Law Specialty Credit Hour. (Tentative)