June 03, 2011 | New York Law Journal
Real Estate Workouts: Cancellation of Indebtedness Income, Part IIIIn his Real Estate Securities column, Proskauer Rose partner Peter M. Fass discusses cancellation of indebtedness income in the context of restructuring or work out of a troubled property owned by a partnership and/or LLC, or a mortgage securing the property where the property does not generate sufficient cash to service the troubled loan or maintain the troubled property.
By Peter M. Fass
10 minute read
February 02, 2005 | New York Law Journal
Real Estate SecuritiesPeter M. Fass, a partner at Proskauer Rose, considers: (1) partial recourse liabilities; (2) tiered partnerships; and (3) the general anti-abuse rule of the 752 Regs
By Peter M. Fass
7 minute read
February 07, 2007 | New York Law Journal
Real Estate SecuritiesPeter M. Fass, a partner at Proskauer Rose, reviews the conditions in the IRS guidelines for obtaining a ruling on whether the co-ownership of rental real property, classified as a tenancy-in-common (TIC) under local law, will be treated as a partnership for tax purposes or as a TIC.
By Peter M. Fass
11 minute read
February 05, 2002 | New York Law Journal
Real Estate SecuritiesP revious columns 1 in this space have discussed the rules dealing with the allocation of income and loss for a partnership or a limited liability company taxed as a partnership, principally discussing �704(b) of the Code and regulations thereunder. 2 This column will discuss the allocation of income and loss when there is a change in the partners` relative interests in the partnership during a year. This can occur by the admission of new partners; the withdrawal of old partners; transfers of partnership i
By Peter M. Fass
8 minute read
August 01, 2007 | New York Law Journal
Real Estate SecuritiesPeter M. Fass, a partner at Prosskauer Rose, discusses the rules of the National Association of Securities Dealers Inc. applicable to TIC interests being securities.
By Peter M. Fass
10 minute read
December 07, 2005 | New York Law Journal
Real Estate SecuritiesPeter M. Fass, a partner at Proskauer Rose, concludes his discussion of �752 Regulations with a review of the effective date of such regulations and the various elections that were available to taxpayers under the various versions of the proposed regulations that preceded the 752 Regs.
By Peter M. Fass
15 minute read
April 06, 2011 | New York Law Journal
Real Estate Workouts: Cancellation Of Indebtedness Income (Part II)In his Real Estate Securities column, Peter M. Fass, a partner at Proskauer Rose, continues his discussion of key issues that an owner of a troubled property faces when restructuring or working out a mortgage secured by a property that does not generate sufficient cash to service the troubled loan or maintain the property.
By Peter M. Fass
11 minute read
June 01, 2005 | New York Law Journal
Real Estate SecuritiesPeter M. Fass, a partner at Proskauer Rose, continues a discussion on the sharing of nonrecourse liabilities under the �752 Regulations for purposes of determining a partner's basis in his partnership interest.
By Peter M. Fass
11 minute read
February 03, 2010 | New York Law Journal
Real Estate SecuritiesPeter M. Fass, a partner at Proskauer Rose, concludes his discussion of the offer and sale of unregistered tax advantaged securities using the Internet, discussing third party informational services.
By Peter M. Fass
9 minute read
August 06, 2002 | New York Law Journal
Real Estate SecuritiesT HIS COLUMN continues the discussion 1 of the issues relating to a contribution of property to a partnership where the tax basis to the contributing partner is more or less than the property`s value. We will examine the basic principles of the regulations adopted under �704(c)(1). 2
By Peter M. Fass
7 minute read
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