EST2601. Income and Wealth Transfer Tax Planning for Real Estate Investors

This presentation focuses on income tax and wealth transfer tax planning opportunities and potential pitfalls for real estate investors, including key non‑tax considerations and practical obstacles. Participants will explore planning strategies for common asset types and ownership structures used in real estate transactions, primarily through hypothetical fact patterns. Topics addressed include the use of grantor trusts, trustee selection, negative capital accounts, opportunity zone planning, transfers of “promote” (i.e., carried) interests, charitable gifts, and related planning considerations.

Learning Objectives:

• Analyze wealth transfer tax opportunities uniquely situated for owners and developers of real property, including a discussion of alternative planning structures.
• Identify income tax planning opportunities for owners and developers of real property and understand the income tax consequences, sometimes involving trade-offs, of wealth transfer tax planning strategies.
• Determine the effects of valuation discounts.
• Analyze non-tax considerations relevant to tax planning strategies — control, cash flow, creditor protection, lender considerations, etc.