2014 Tax Overview

February 13, 2014
Fox Rothschild LLP
PGA National Resort & Spa

400 Avenue of the Champions
Palm Beach Gardens, FL 33418

11:30 a.m. to 6 p.m.

Noon to 1 p.m. – Lunch With Christian Searcy of UBS

1 to 2 p.m. – Tax Structuring for Foreign Investment in U.S. Real Estate

This presentation will focus on the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) and related withholding provisions, an understanding of which is key in structuring foreign capital investment in U.S. real estate. Additional topics will include loan structures in lieu of or complementary to equity investments in U.S. real estate, related income tax treaty issues and an overview of salient transfer tax issues.

3:15 to 4:45 p.m. – Update on Planning for Creating, Operating and Unwinding Family Limited Partnerships and Limited Liability Companies

Speakers: Joseph J. Kulunas, Partner, Taxation and Wealth Planning Department, Fox Rothschild

The IRS continues to attack the family limited partnership or limited liability company from being used to reduce federal gift and transfer tax liabilities of taxpayers in passing on highly valued assets to members of their family. This discussion will note the relevant federal transfer and income tax provisions in creating, operating and unwinding such entities and the important as well as recently issued court decisions on the challenges made by the IRS. The speakers will use illustrations and examples as part of their presentation.

5 to 6 p.m. – Cocktail Networking Reception

PGA National Resort & Spa
400 Avenue of the Champions
Palm Beach Gardens, FL 33418

This program will offer both CLE and CPE credits.

CLE Credits

California CLE 3.5 General

Florida CLE 3.5 (Pending) General

New Jersey CLE 3.5 General

New York CLE 3.5 PP/PM (Reciprocal)

CPE Credits

4.0 Credits for Florida, New Jersey, New York and Pennsylvania