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- Title
Real Estate Investment Trust Corner.
- Authors
Cullen, Daniel F.
- Abstract
The article discusses the tax issues in relation to Code Sec. 752 gain which may arise in an umbrella-partnership real estate investment trust (UPREIT) deal. It says that nonrecourse debt allocation rules may produce taxable gain for contributing partners. It tackles the nonrecourse indebtedness (NRD) allocation approach which includes partner minimum gain, built-in gain, and substantial effects. It adds that contributors may enter into bottom dollar guarantee deals to address the gain.
- Subjects
TAXATION of real estate investment trusts; NONRECOURSE debt; INCOME tax; BUSINESS partnerships; MINIMUM income tax; SURETYSHIP &; guaranty
- Publication
Journal of Passthrough Entities, 2010, Vol 13, Issue 3, p25
- ISSN
1099-7407
- Publication type
Article