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Tax Risks in Promoted 453 Transactions

TAX RISKS IN PROMOTED 453 TRANSACTIONS

Cost Free
Presentation Length 1.0 hour

Recorded DateFebruary 29, 2024
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

Recent proposed regulations classify monetized installment sale (MIS) transactions as listed transactions with special reporting requirements. This guidance has put the spotlight on intermediary installment sale (IIS) transactions, the larger family of transactions of which MIS transactions are a part. Intermediary installment sale transactions use the installment method of accounting to add tax savings to cash sales of appreciated property. This technique is often marketed as an alternative to a 1031 exchange. This webinar will discuss IRS guidance on these transactions and possible risks.  

Learning Objectives:


  • Summarize proposed regulations related to MIS transactions and their significance

  • Identify and learn to explain IIS transactions to clients

  • Define how to advise clients concerning the risks of a transaction being considered “substantially similar” to an MIS

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PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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Matthew E. Rappaport concentrates his practice in Taxation related to Real Estate, Corporations, Partnerships, and Trusts & Estates. He advises clients regarding tax planning and structuring for generational wealth transfer, commercial real estate enterprises, business transactions, and cross-border considerations. He primarily advises real estate professionals, financial professionals, and closely-held business owners. He also functions as a subcontractor for other attorneys, accountants, financial advisors, bankers, and insurance professionals when they encounter matters requiring a threshold level of tax law expertise.

Mr. Rappaport graduated from Washington University in St. Louis in 2007, cum laude, with an undergraduate degree in Political Science. His undergraduate thesis was a cross-sectional analysis of the corporate culture of the privately held financial firm Edward Jones. He received his Juris Doctor and Master of Laws in Taxation from Georgetown University Law Center in 2011. Mr. Rappaport is licensed to practice in New York. He is an active member of the Nassau County Bar Association, the New York State Bar Association, and the American Bar Association. He was the Co-Vice Chair of the Tax Committee of the Nassau County Bar Association from June 2015 until June 2016.

He serves on the Sales, Exchanges, and Basis Committee of the American Bar Association Section of Taxation. Mr. Rappaport has authored articles for the Nassau Lawyer, Thomson Reuters’ Journal of Real Estate Taxation, The Tax Adviser, Bloomberg BNA’s Tax Management – Real Estate Journal, and the Journal of Taxation of Investments. He has spoken at the request of the American Bar Association, the National Conference of CPA Practitioners, the Financial Planning Association, Strafford Publications, the School of Accounting at LIU Post, and a wide variety of law, accounting, and wealth advisory firms. He is a founder of the young professionals networking group Hydra Collective.

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Andrew is a Partner and co-chairs FRB’s Taxation Practice Group. He advises clients on a wide range of federal and international tax matters, including deferral and characterization of income; partnership taxation; corporate taxation; and Opportunity Zones. He frequently represents closely held family businesses, real estate developers, and cannabis clients. He also has extensive experience in estate and gift tax planning.

Andrew’s articles on Opportunity Zones have appeared in Tax Notes, Bloomberg, California Tax Lawyer, and elsewhere. He is a frequent contributor to educational materials for California CEB (Continuing Education of the Bar) and has been quoted in the Wall Street Journal on the topic of foreign tax shelters. 

Andrew started his career at the US Attorney’s Office in the Eastern District of California, prosecuting misdemeanors on federal land. He was also a federal judicial clerk and a staff attorney at the Ninth Circuit Court of Appeals. These government experiences inform his judgment in offering opinions on uncertain tax matters.

About Our Presenter

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Matthew E. Rappaport concentrates his practice in Taxation as it relates to Real Estate, Corporations, Partnerships, and Trusts & Estates. He advises clients regarding tax planning and structuring for generational wealth transfer, commercial real estate enterprises, business transactions, and cross-border considerations. He primarily advises real estate professionals, financial professionals, and closely held business owners. He also functions like a subcontractor for other attorneys, accountants, financial advisors, bankers, and insurance professionals when they encounter matters requiring a threshold level of tax law expertise.