Attention:

CARES Act and Partnerships: Navigating Time-Sensitive Issues and Refund Opportunities


Level: Advanced
Runtime: 93 minutes
Recorded Date: May 05, 2020
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Agenda

  • Procedural Guidance
  • CARES Act: Path to Access Cash
  • Real Estate Related Opportunities and Guidance

Runtime: 1 hour, 33 minutes
Recorded: May 5, 2020

Description

This panel will offer an overview of the tax provisions of the CARES Act affecting partnerships and their partners, as well as procedural guidance issued by the IRS in the wake of the legislation. Special attention will be given to real estate and refund opportunities.

Topics include filing deadline extensions, amendments to previously filed partnership returns, NOL carrybacks and tentative refund claims, changes to business interest limitation, technical correction to depreciation of qualified improvement property, and postponement of excess business loss rules.

The panel will also address deadline extensions applicable to section 1031 exchanges and opportunity zone investments. 

This program was recorded on May 5th, 2020.

Provided By

American Bar Association

Panelists

Shamik Trivedi

Special Counsel, Office of Chief Counsel
IRS

Shamik Trivedi is a Special Counsel at the IRS Office of Chief Counsel.

Sarah Ritchey Haradon

Partner
Holland & Hart LLP

Sarah advises clients on a broad range of corporate, partnership, and individual income tax matters, including joint ventures, mergers and acquisitions, restructurings, and IRS audits, appeals, and litigation.

Her practice primarily involves representing companies and individuals in complex transactions as well as against the Internal Revenue Service. She helps companies and individuals achieve optimal tax efficiency in their business operations through formations, sales and restructurings. She also has experience with every aspect of the IRS administrative process, including representing clients in front of the United States Tax Court.

Prior to joining Holland & Hart, Sarah worked for Miller & Chevalier Chartered in Washington, D.C. She also clerked for the United States Tax Court and practiced in the area of corporate finance, developing a broad range of experience in debt and equity transactions.

While at Georgetown University Law Center, she served as a legal fellow with the Council on State Taxation, where she worked on amicus briefs in support of taxation issues relevant to organization members, namely large multinational corporations.

Monisha Santamaria

Lesgislation Counsel
Joint Committee of Taxation

Monisha Santamaria is a Legislation Counsel at the Joint Committee of Taxation. Previously, Monisha was a senior manager in Ernst & Young LLP’s National Tax Department, advising clients on a wide range of U.S. federal income tax issues impacting domestic and foreign partnerships. Before joining Ernst & Young in 2015, she was an associate in the Los Angeles office of Skadden, Arps, Slate, Meagher & Flom LLP. There, she primarily counseled multinational corporations on the U.S. federal income tax aspects of joint ventures, mergers, acquisitions, and divestitures. Prior to that, Monisha was an associate in the Washington, DC office of Bingham McCutchen LLP, chiefly serving Fortune 50, financial sector, and energy industry clients. There, she concentrated her practice on tax planning, with a special focus on issues at the intersection of partnership, corporate, and international tax.

Monisha is an active member of the ABA and the profession generally. She serves as the CLE chair of the ABA Section of Taxation’s Partnership Committee. Monisha is a frequent speaker at conferences and previously taught an advanced partnership tax course at the Loyola Law School. She has published extensively on a variety of tax law issues.

Monisha holds a J.D. from Stanford Law School.

Mark E. Wilensky

Partner
Meltzer Lippe Goldstein & Breistone, LLP

Mark E. Wilensky is a partner in the firm’s Business & Real Estate Taxation Practice Group. Prior to joining the firm Mark was a tax attorney in the New York City office of Roberts & Holland LLP for twelve years.

In September 2017, Mark was elected a Fellow of the American College of Tax Counsel (or “ACTC”) in recognition of his exceptional degree of professional commitment to the practice of tax law. ACTC is a nonprofit professional association of tax lawyers in private practice, in law school teaching positions and in government who are recognized for their excellence in tax practice and for their substantial contributions and commitment to the profession.

A large part of Mark’s practice involves advising clients looking to sell, exchange, lease, or refinance real estate and take advantage of the tax deferral opportunities offered by section 1031 exchanges, installment sales, and long-term lease agreements. Mark frequently works with real estate counsel at the Firm advising clients operating as partnerships, limited liability companies, or S corporations on ways to achieve tax deferral from an exchange of property without triggering gain from receipt of taxable “boot.”

Another large part of Mark’s practice involves working with the Firm’s corporate counsel advising business entities on ways to divide a business among shareholders or partners without triggering taxable gain or otherwise counseling clients operating as limited liability companies or S corporations on ways to take advantage of the lower tax rates on capital gains when selling all or a portion of a business.

Mark also has experience settling New York State and City residency audits and advising clients on New York State and City real estate transfer tax, mortgage recording tax, and sales taxes.

Mark chaired the American Bar Association Tax Section’s Sales, Exchanges & Basis Committee (presiding over section 1031 practice) from 2012 through June 2014 and is a frequent speaker at Tax Section meetings. Mark was honored by the Tax Section as a Nolan Fellow in 2011. Mark is a member of the Bloomberg BNA Pass Through Entities Advisory Board.

Mark, testified at the Department of Treasury/IRS hearing in Washington D.C. on the proposed Treasury regulations regarding investments in Qualified Opportunity Funds. Mark had principal responsibility for the ABA Tax Section’s comments on the proposed regulations that were submitted to members of the Department of Treasury and the IRS in January 2019.

Some of Mark’s recent presentations include a discussion of the tax treatment of so-called “drop & swap” section 1031 exchanges, changes to the federal partnership audit rules, planning for the new federal 20% deduction for pass-through entities, and tax planning for investments in qualified opportunity zones.

Mark has taught the Federal Income Tax course at Hofstra School of Law and Taxation of Real Estate Transactions at Cardozo School of Law. He has also guest lectured on section 1031 exchanges at New York University’s Stern School of Business.

Mark brings a sense of humor to the table. An improv enthusiast, Mark regularly takes classes with some of New York City’s finest improv performers and periodically takes the stage himself with his classmates for performances at venues in New York City.

Jon G. Finkelstein

Principal
KPMG

Jon G. Finkelstein primarily focuses on providing tax planning advice to partnerships, limited liability companies, and other passthrough entities. Jon has significant experience in structuring complex joint ventures, restructurings, acquisitions, and dispositions involving real estate funds, operating businesses, and real estate assets.

Jon is a former Chair of both the Real Estate Committee of the American Bar Association (Tax Section) and the Passthroughs and Real Estate Committee of the District of Columbia Bar Association (Tax Section). Jon is also an adjunct professor at Georgetown University Law School and the Villanova University Graduate Tax Program.

Jon frequently publishes articles in leading tax publications and speaks at professional conferences across the country.

Prior to joining KPMG, Jon was a partner at McDermott Will & Emery LLP, an international law firm.

Jon has a JD degree, magna cum laude, from the University of Minnesota, and a BA degree from Columbia University.


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