ABA’s Section of Taxation: 2023 Midyear Tax Meeting

Jessica Millett will be a panelist in a session titled "Hot Topics," on 10 February at 3:00 p.m., which will focus on hot topics for real estate and partnerships. Among other topics, this panel will discuss the energy tax incentives for real estate in the Inflation Reduction Act of 2022.

Attendees of this session will be able to:

• Learn about recent changes in law including those stemming from the Inflation Reduction Act and new guidance issued by the IRS.
• Understand the new energy tax incentives for real estate.
• Learn about the changes to the definition of qualified foreign pension funds and the rules under Section 892 and 897.

Lauren Clarke will serve as panelist in the following session titled "UPREIT and DownREIT Property Contributions," beginning at 3:45 p.m. (PST) This panel will discuss the tax issues faced by contributors and REITs in UPREIT and DownREIT property contributions transactions, including negotiating tax protection agreements and protecting negative tax capital accounts.

Attendees of this session will be able to:

• Understand tax issues faced in property contribution transactions involving UPREITs and DownREITs.
• Learn about negotiating tax protection agreements.
• Learn about protecting negative tax capital accounts.

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