Stephen M. Breitstone and Jerome M. Hesch will be speaking at the NYU 81st Institute on Federal Taxation in New York City on Wednesday, October 26, 2022 and in San Diego on Wednesday, November 16, 2022 on a panel entitled “Increasing the income and estate tax benefits of the preferred partnership with encumbered real estate by future leveraging.”
The preferred partnership for encumbered real estate has been used to accomplish both an income tax free basis at death for the preferred partnership interest included in the decedent’s taxable estate and an estate freeze by disposing of the common interest while the decedent is living The step-up in basis at death is especially attractive for encumbered real estate with a negative capital account. The presenters first describe how the formation of the preferred partnership and the transfer of the common interest to a grantor trust implement the income tax and estate tax savings available at the time the preferred partnership is formed. The presenters then describe how future refinancings of the real estate can increase the amount of negative capital account gain eliminated by inclusion of the preferred interest in the decedent’s estate while simultaneously decreasing the value for the preferred interest included in the estate and shifting more value to the common interest.
For more information and to register, please visit https://bit.ly/3fYnczw.