This document provides an overview of 1031 exchanges, which allow taxpayers to defer capital gains taxes when selling business or investment property and reinvesting the proceeds into like-kind replacement property. Key points include the tax code section allowing 1031 exchanges, the identification and exchange periods for delayed exchanges, the rules for like-kind properties, and safe harbors provided in the regulations for qualified intermediaries, escrow accounts, and trusts.
This document provides a summary of a presentation titled "Section 1031 Exchanges in the 21st Century – Regulatory Changes and Case Law Impact". The presentation discusses IRS code Section 1031 which allows for the deferral of capital gains taxes when property held for business or investment is exchanged for like-kind property. It covers topics such as what qualifies as like-kind property, identification and exchange time periods, qualified intermediary requirements, Treasury Inspector General reports on qualified intermediaries, and considerations for choosing a qualified intermediary.
Trustees have several key duties under trust law:
1) Act in accordance with the terms of the trust deed.
2) Familiarize themselves with the trust terms and ensure trust properties are properly vested.
3) Convert speculative or non-income producing investments to provide income for beneficiaries.
4) Provide information and accounts to beneficiaries regarding the trust fund and properties.
5) Distribute trust properties to the proper beneficiaries.
This document discusses the law of trusts in different jurisdictions. It begins by outlining the four essential elements of an English trust: trust property, trustee, beneficiaries, and a deed or instructions. It then examines trusts in Japan, noting they developed differently due to Japanese concepts of family estates. China's new Trust Law from 2001 was influenced by laws from Taiwan, Japan, Korea and Anglo-American systems, and aimed to enhance China's economic development. Implementing this borrowed statute poses challenges as some principles conflict with Anglo-American trust law.
Chapter 32 – Negotiation and Holder in Due CourseUAF_BA330
This document provides a 3-page summary of key concepts related to negotiation and holders in due course of negotiable instruments. It begins by explaining the process of transferring negotiable instruments from one person to another, distinguishing between order paper and bearer paper. It then discusses the requirements for negotiation, types of endorsements, and effects of endorsement. The summary concludes by outlining the requirements to achieve holder in due course status and the rights and limitations of a holder in due course.
1) The document discusses the nature and scope of a Registrar's Caveat under Section 320(1) of the National Land Code, which allows the Registrar to enter a caveat on land to protect against fraud or improper dealings or to protect certain interests.
2) It outlines the Registrar's powers to enter a caveat and the circumstances under which a caveat can be entered. An aggrieved party can appeal the Registrar's decision or apply to have the caveat removed.
3) The effect of a caveat is to prevent dealings on the disputed land. A caveat does not have an expiration date and continues until cancelled by the Registrar either on their
1. A private caveat is entered on the land title register upon application, to protect a title or interest claimed in the land until any disputes are settled.
2. The effect of a private caveat is that it prevents any dealings with the land, such as transfers of ownership, from being registered unless the caveator consents. However, it does not change the ownership of the land or strengthen the caveator's claim.
3. To enter a private caveat, the caveator must have a caveatable interest in the land, such as a claim to ownership or registered interest, and submit the required application form and statutory declaration to the registrar. The registrar's role is administrative and they must
The Personal Property Securities Act establishes a national online register for security interests in personal property and will take effect from January 2012, subsuming various state registers; it aims to improve business access to capital by clarifying rules around secured loans, leases, retention of title and more; the document provides an overview of who is affected and their obligations to register under the new system.
A private caveat is an interim procedure that allows a person claiming a title or registrable interest in land to freeze the land title registration until their claim can be resolved. A private caveat is entered by the Registrar upon application showing the claimant's caveatable interest. It has the effect of prohibiting any dealings with the land, including transfers or mortgages, except with the caveator's consent. To enter a caveat, the claimant must have a potential legal claim to the land, such as under a contract of sale, gift, or trust, that could ultimately result in registration of their interest.
This document provides a summary of a presentation titled "Section 1031 Exchanges in the 21st Century – Regulatory Changes and Case Law Impact". The presentation discusses IRS code Section 1031 which allows for the deferral of capital gains taxes when property held for business or investment is exchanged for like-kind property. It covers topics such as what qualifies as like-kind property, identification and exchange time periods, qualified intermediary requirements, Treasury Inspector General reports on qualified intermediaries, and considerations for choosing a qualified intermediary.
Trustees have several key duties under trust law:
1) Act in accordance with the terms of the trust deed.
2) Familiarize themselves with the trust terms and ensure trust properties are properly vested.
3) Convert speculative or non-income producing investments to provide income for beneficiaries.
4) Provide information and accounts to beneficiaries regarding the trust fund and properties.
5) Distribute trust properties to the proper beneficiaries.
This document discusses the law of trusts in different jurisdictions. It begins by outlining the four essential elements of an English trust: trust property, trustee, beneficiaries, and a deed or instructions. It then examines trusts in Japan, noting they developed differently due to Japanese concepts of family estates. China's new Trust Law from 2001 was influenced by laws from Taiwan, Japan, Korea and Anglo-American systems, and aimed to enhance China's economic development. Implementing this borrowed statute poses challenges as some principles conflict with Anglo-American trust law.
Chapter 32 – Negotiation and Holder in Due CourseUAF_BA330
This document provides a 3-page summary of key concepts related to negotiation and holders in due course of negotiable instruments. It begins by explaining the process of transferring negotiable instruments from one person to another, distinguishing between order paper and bearer paper. It then discusses the requirements for negotiation, types of endorsements, and effects of endorsement. The summary concludes by outlining the requirements to achieve holder in due course status and the rights and limitations of a holder in due course.
1) The document discusses the nature and scope of a Registrar's Caveat under Section 320(1) of the National Land Code, which allows the Registrar to enter a caveat on land to protect against fraud or improper dealings or to protect certain interests.
2) It outlines the Registrar's powers to enter a caveat and the circumstances under which a caveat can be entered. An aggrieved party can appeal the Registrar's decision or apply to have the caveat removed.
3) The effect of a caveat is to prevent dealings on the disputed land. A caveat does not have an expiration date and continues until cancelled by the Registrar either on their
1. A private caveat is entered on the land title register upon application, to protect a title or interest claimed in the land until any disputes are settled.
2. The effect of a private caveat is that it prevents any dealings with the land, such as transfers of ownership, from being registered unless the caveator consents. However, it does not change the ownership of the land or strengthen the caveator's claim.
3. To enter a private caveat, the caveator must have a caveatable interest in the land, such as a claim to ownership or registered interest, and submit the required application form and statutory declaration to the registrar. The registrar's role is administrative and they must
The Personal Property Securities Act establishes a national online register for security interests in personal property and will take effect from January 2012, subsuming various state registers; it aims to improve business access to capital by clarifying rules around secured loans, leases, retention of title and more; the document provides an overview of who is affected and their obligations to register under the new system.
A private caveat is an interim procedure that allows a person claiming a title or registrable interest in land to freeze the land title registration until their claim can be resolved. A private caveat is entered by the Registrar upon application showing the claimant's caveatable interest. It has the effect of prohibiting any dealings with the land, including transfers or mortgages, except with the caveator's consent. To enter a caveat, the claimant must have a potential legal claim to the land, such as under a contract of sale, gift, or trust, that could ultimately result in registration of their interest.
Registrar's Caveat under Land Law II.
Contains;
1. Function of a Registrar
2. Effects of Registrar's Caveat
3. Who can apply for Registrar's Caveat
4. Remedy of an Aggrieved Party under RC
5. Cases involved
Trust Caveat under Land Law II syllabus. Containing definition, nature and effect of Trust Caveat, Duration under Section 333 of the NLC. Express Trust also is included in this slide. Creation of Trust Caveat under NLC, its' effect & the person eligible in entering into Trust Caveat.
Three key points about real estate in Colombia:
1. Colombian and foreign nationals have equal rights to purchase property.
2. Real estate transactions do not impose additional taxes, legal, or financial burdens on foreign investors.
3. Land use must comply with municipal regulations and zoning laws.
This document provides definitions and outlines the life cycle of a negotiable instrument according to negotiable instruments law. It defines key terms like promissory note, bill of exchange, bearer, holder, and types of indorsements. It also summarizes the requirements for an instrument to be negotiable, including being in writing and signed, containing an unconditional promise to pay a sum certain on demand or at a future date, and being payable to order or bearer. The document outlines the transfer and negotiation process, including delivery, types of indorsements, and rights and liabilities of parties.
Trustees have both powers and duties. Their powers include selling trust property, insuring assets, compounding liabilities, maintaining and advancing funds to beneficiaries. Their key duties are to protect trust assets, treat beneficiaries equally, provide beneficiaries with account information, and properly distribute trust funds. Trustees must exercise their powers and duties with care, skill, prudence and in the sole interest of beneficiaries.
LAW OF TRUST(BUSINESS LAW) BY RIZWAN KHATTAKRizwan Khattak
The document discusses the law of trusts in Pakistan. It defines a trust and key terminology like author of trust, trustee, beneficiary, trust property, etc. It explains the lawful and unlawful purposes of a trust. The responsibilities of a trustee are to accomplish the trust purpose according to the instrument of trust, protect the trust property, not set up adverse titles, deal with the property carefully, convert wasting property, be impartial, and more. Trustees can be discharged by completion of duties, appointment of a new trustee, consent of beneficiaries, or by court order. A new trustee can be appointed if the existing trustee dies, disclaims, is absent or insolvent.
Would a country like Germany be allowed to prohibit the ownership and trade of Bitcoin, as is the case in China? Dennis Hillemann of www.blockchainlawyersnetwork.com treated this topic in a lecture on 9.9.2020 from a constitutional viewpoint. Does the German constitution protect Bitcoin? Please find attached the presentation on this legal matter in the blockchain and cryptocurrency space.
1) The document discusses land acquisition in Malaysia, outlining the relevant constitutional provisions and legislation governing compulsory acquisition of private land by the state.
2) It examines the Land Acquisition Act 1960 which consolidates previous state enactments and is based on the concept of "eminent domain", giving the government an inherent right to acquire private land for public use subject to compensation.
3) The scope of acquiring powers under the Act is explored, including amendments that expanded the definition of "public purpose" to include purposes beneficial to economic development or the public. The procedures for land acquisition applications and declarations are also summarized.
The Power of Section 1031 for Accounting ProfessionalsEdmund_Wheeler
The document discusses Section 1031 like-kind exchanges, which allow taxpayers to defer capital gains taxes when selling business or investment property and replacing it with similar property. Key points include:
1) Section 1031 exchanges allow taxpayers to defer capital gains taxes by exchanging eligible investment or business use properties for other like-kind properties through a qualified intermediary.
2) There are strict rules regarding identification of replacement properties within 45 days and completion of the acquisition within 180 days to qualify for tax deferral.
3) Common misconceptions are that exchanges must involve other property owners or close simultaneously, but Section 1031 allows for deferred exchanges through qualified intermediaries.
Shhhhh. Don't tell anyone. Your clients are eligible for interest free loans from the US and State Governments for as long as they'd like and as many times as they'd like for commercial real estate transactions. Only 3% of the approximately $200 billion in commercial real estate transactions during 2008 took advantage of Section 1031 treatment, which allows taxpayers to defer capital gains taxes when exchanging real estate properties. The document discusses the benefits of Section 1031 exchanges for clients and attorneys, including being able to use tax deferred money to enhance property holdings and as an estate planning tool.
This document provides an overview of Section 1031 exchanges, which allow taxpayers to defer capital gains taxes when exchanging investment or business use real estate for other qualifying like-kind property. Key points covered include the benefits of full tax deferral, rules around identifying replacement properties within 45 days and acquiring them within 180 days, using a qualified intermediary, qualifying property types including exchanges into partnerships or oil/gas interests, and alternative exchange strategies like structured sales.
The 1031 exchange allows real estate investors to defer capital gains taxes when selling investment or business property and purchasing a new replacement property. Key aspects include exchanging property of like-kind to defer all capital gains taxes, using a qualified intermediary to handle transaction funds and identifying a replacement property within 45 days. Following the guidelines of a 1031 exchange can help investors consolidate, diversify or improve their real estate portfolio in a tax advantageous way.
A 1031 exchange allows real estate investors to sell property and use the proceeds to purchase similar replacement property without paying capital gains taxes, provided certain requirements are met, including identifying and purchasing the replacement property within strict time limits. The exchange process provides tax benefits and opportunities to improve an investor's real estate portfolio by upgrading or diversifying properties. Qualified intermediaries facilitate delayed exchanges to help ensure transactions meet IRS rules for deferred tax treatment.
The document provides an outline for a course on advanced IRC Section 1031 exchange concepts. It covers exchange terminology, definitions of like-kind property, delayed and reverse exchanges, boot, identification and exchange periods, restrictions on exchange proceeds, related party rules, and issues around vacation homes and tenant-in-common ownership structures.
The term 1031 Exchange is defined under section 1031 of the IRS Code. To put it simply, this strategy allows an investor to “defer” paying capital gains taxes on an investment property when it is sold, as long another “like-kind property” is purchased with the profit gained by the sale of the first property.
The document provides guidance on section 1031 like-kind exchanges, including the basic tax principles for deferred exchanges, the key elements of a qualifying like-kind exchange, and examples of private letter rulings related to issues like treatment of failed like-kind exchanges and transfers of development rights.
A 1031 exchange allows real estate investors to defer capital gains taxes when selling investment or business use property and reinvesting the proceeds into another qualifying property. Key benefits include deferring capital gains taxes of up to 20%, leveraging funds, and upgrading or diversifying property holdings. To qualify, the replacement property must be identified within 45 days and received within 180 days of the relinquished property sale. This allows proceeds to be reinvested tax-free through either simultaneous or delayed exchange structures.
This document provides an overview of like-kind exchanges under Internal Revenue Code Section 1031. It discusses the key requirements for completing a tax-deferred like-kind exchange, including using a qualified intermediary, identifying and purchasing replacement property within the required timeframes, and restricting rights to receipt of proceeds. It also summarizes some of the common types of real property and personal property that qualify for like-kind exchange treatment.
Registrar's Caveat under Land Law II.
Contains;
1. Function of a Registrar
2. Effects of Registrar's Caveat
3. Who can apply for Registrar's Caveat
4. Remedy of an Aggrieved Party under RC
5. Cases involved
Trust Caveat under Land Law II syllabus. Containing definition, nature and effect of Trust Caveat, Duration under Section 333 of the NLC. Express Trust also is included in this slide. Creation of Trust Caveat under NLC, its' effect & the person eligible in entering into Trust Caveat.
Three key points about real estate in Colombia:
1. Colombian and foreign nationals have equal rights to purchase property.
2. Real estate transactions do not impose additional taxes, legal, or financial burdens on foreign investors.
3. Land use must comply with municipal regulations and zoning laws.
This document provides definitions and outlines the life cycle of a negotiable instrument according to negotiable instruments law. It defines key terms like promissory note, bill of exchange, bearer, holder, and types of indorsements. It also summarizes the requirements for an instrument to be negotiable, including being in writing and signed, containing an unconditional promise to pay a sum certain on demand or at a future date, and being payable to order or bearer. The document outlines the transfer and negotiation process, including delivery, types of indorsements, and rights and liabilities of parties.
Trustees have both powers and duties. Their powers include selling trust property, insuring assets, compounding liabilities, maintaining and advancing funds to beneficiaries. Their key duties are to protect trust assets, treat beneficiaries equally, provide beneficiaries with account information, and properly distribute trust funds. Trustees must exercise their powers and duties with care, skill, prudence and in the sole interest of beneficiaries.
LAW OF TRUST(BUSINESS LAW) BY RIZWAN KHATTAKRizwan Khattak
The document discusses the law of trusts in Pakistan. It defines a trust and key terminology like author of trust, trustee, beneficiary, trust property, etc. It explains the lawful and unlawful purposes of a trust. The responsibilities of a trustee are to accomplish the trust purpose according to the instrument of trust, protect the trust property, not set up adverse titles, deal with the property carefully, convert wasting property, be impartial, and more. Trustees can be discharged by completion of duties, appointment of a new trustee, consent of beneficiaries, or by court order. A new trustee can be appointed if the existing trustee dies, disclaims, is absent or insolvent.
Would a country like Germany be allowed to prohibit the ownership and trade of Bitcoin, as is the case in China? Dennis Hillemann of www.blockchainlawyersnetwork.com treated this topic in a lecture on 9.9.2020 from a constitutional viewpoint. Does the German constitution protect Bitcoin? Please find attached the presentation on this legal matter in the blockchain and cryptocurrency space.
1) The document discusses land acquisition in Malaysia, outlining the relevant constitutional provisions and legislation governing compulsory acquisition of private land by the state.
2) It examines the Land Acquisition Act 1960 which consolidates previous state enactments and is based on the concept of "eminent domain", giving the government an inherent right to acquire private land for public use subject to compensation.
3) The scope of acquiring powers under the Act is explored, including amendments that expanded the definition of "public purpose" to include purposes beneficial to economic development or the public. The procedures for land acquisition applications and declarations are also summarized.
The Power of Section 1031 for Accounting ProfessionalsEdmund_Wheeler
The document discusses Section 1031 like-kind exchanges, which allow taxpayers to defer capital gains taxes when selling business or investment property and replacing it with similar property. Key points include:
1) Section 1031 exchanges allow taxpayers to defer capital gains taxes by exchanging eligible investment or business use properties for other like-kind properties through a qualified intermediary.
2) There are strict rules regarding identification of replacement properties within 45 days and completion of the acquisition within 180 days to qualify for tax deferral.
3) Common misconceptions are that exchanges must involve other property owners or close simultaneously, but Section 1031 allows for deferred exchanges through qualified intermediaries.
Shhhhh. Don't tell anyone. Your clients are eligible for interest free loans from the US and State Governments for as long as they'd like and as many times as they'd like for commercial real estate transactions. Only 3% of the approximately $200 billion in commercial real estate transactions during 2008 took advantage of Section 1031 treatment, which allows taxpayers to defer capital gains taxes when exchanging real estate properties. The document discusses the benefits of Section 1031 exchanges for clients and attorneys, including being able to use tax deferred money to enhance property holdings and as an estate planning tool.
This document provides an overview of Section 1031 exchanges, which allow taxpayers to defer capital gains taxes when exchanging investment or business use real estate for other qualifying like-kind property. Key points covered include the benefits of full tax deferral, rules around identifying replacement properties within 45 days and acquiring them within 180 days, using a qualified intermediary, qualifying property types including exchanges into partnerships or oil/gas interests, and alternative exchange strategies like structured sales.
The 1031 exchange allows real estate investors to defer capital gains taxes when selling investment or business property and purchasing a new replacement property. Key aspects include exchanging property of like-kind to defer all capital gains taxes, using a qualified intermediary to handle transaction funds and identifying a replacement property within 45 days. Following the guidelines of a 1031 exchange can help investors consolidate, diversify or improve their real estate portfolio in a tax advantageous way.
A 1031 exchange allows real estate investors to sell property and use the proceeds to purchase similar replacement property without paying capital gains taxes, provided certain requirements are met, including identifying and purchasing the replacement property within strict time limits. The exchange process provides tax benefits and opportunities to improve an investor's real estate portfolio by upgrading or diversifying properties. Qualified intermediaries facilitate delayed exchanges to help ensure transactions meet IRS rules for deferred tax treatment.
The document provides an outline for a course on advanced IRC Section 1031 exchange concepts. It covers exchange terminology, definitions of like-kind property, delayed and reverse exchanges, boot, identification and exchange periods, restrictions on exchange proceeds, related party rules, and issues around vacation homes and tenant-in-common ownership structures.
The term 1031 Exchange is defined under section 1031 of the IRS Code. To put it simply, this strategy allows an investor to “defer” paying capital gains taxes on an investment property when it is sold, as long another “like-kind property” is purchased with the profit gained by the sale of the first property.
The document provides guidance on section 1031 like-kind exchanges, including the basic tax principles for deferred exchanges, the key elements of a qualifying like-kind exchange, and examples of private letter rulings related to issues like treatment of failed like-kind exchanges and transfers of development rights.
A 1031 exchange allows real estate investors to defer capital gains taxes when selling investment or business use property and reinvesting the proceeds into another qualifying property. Key benefits include deferring capital gains taxes of up to 20%, leveraging funds, and upgrading or diversifying property holdings. To qualify, the replacement property must be identified within 45 days and received within 180 days of the relinquished property sale. This allows proceeds to be reinvested tax-free through either simultaneous or delayed exchange structures.
This document provides an overview of like-kind exchanges under Internal Revenue Code Section 1031. It discusses the key requirements for completing a tax-deferred like-kind exchange, including using a qualified intermediary, identifying and purchasing replacement property within the required timeframes, and restricting rights to receipt of proceeds. It also summarizes some of the common types of real property and personal property that qualify for like-kind exchange treatment.
A 1031 exchange, also known as a tax-deferred or like-kind exchange, allows you to defer taxes on gains when you sell a business asset or investment property and purchase another asset that is deemed like-kind. Though they are commonly associated with real estate, any asset held for investment or business use can qualify for a like-kind exchange.
Like-kind exchanges have been an established part of tax law since 1921, but there are still a number of misconceptions about what they are and how they work. Let's clear some of those up!
The document provides an overview of IRC Section 1031, which allows for the tax-deferred exchange of real estate and other investment properties. Key points include:
- Section 1031 has existed since the 1920s and allows investors to defer capital gains taxes by exchanging one property for another of like-kind.
- Common motivations for using Section 1031 exchanges include consolidation, diversification, and increasing cash flow or depreciation.
- Exchanges must meet several rules to fully defer taxes, such as purchasing a replacement property of equal or higher value and reinvesting all sale proceeds.
- There are time limits of 45 days to identify potential replacement properties and 180 days to complete the purchase after
The document discusses using Section 1031 exchanges to defer capital gains taxes when selling investment real estate and purchasing replacement properties. It provides examples of different types of Section 1031 exchange structures including delayed exchanges, reverse exchanges, and build-to-suit exchanges. It also discusses alternative investment opportunities that can be acquired through Section 1031 exchanges, including investing in tenant-in-common properties which provide fractional ownership of institutional-grade real estate. The document aims to educate about Section 1031 exchanges and their strategic benefits for real estate investors and clients.
The document summarizes key changes to 1031 exchanges under the Tax Cuts and Jobs Act, including:
- Personal property exchanges were repealed and replaced with increased immediate expensing of property. Exchanges now only apply to real property held for productive use or investment.
- Examples of personal property now excluded from 1031 exchanges include airplanes, vehicles, artwork, and franchises.
- The document provides an overview of forward and reverse 1031 exchanges and considerations for partnership matters.
- It concludes with answering common questions about 1031 exchange qualifications, timing, the treatment of personal property, related party transactions, and other planning strategies.
This document provides an overview of Internal Revenue Code Section 1031 exchanges, which allow taxpayers to defer capital gains tax when selling investment or business property and reinvesting the proceeds into similar "like-kind" property. Key points covered include what qualifies for a 1031 exchange, requirements and timelines, exchange terminology, strategies for forward and reverse exchanges, benefits for realtors and taxpayers, and common misconceptions about 1031 exchanges.
The document discusses Section 1031 of the Internal Revenue Code, which allows for the nonrecognition of gain or loss from exchanges of property held for productive use in a trade or business or for investment if the property exchanged is "like-kind". It provides an overview of the history of Section 1031 and its key rules regarding time limits for identification and receipt of replacement property, treatment of cash or other property ("boot") received in an exchange, and the use of qualified intermediaries and reverse exchanges.
The document discusses Section 1031 of the Internal Revenue Code, which allows for the nonrecognition of gain or loss from exchanges of property held for productive use in a trade or business or for investment if the property exchanged is "like-kind". It provides an overview of the history of Section 1031 and its key rules regarding time limits for identification and receipt of replacement property, treatment of cash or other property ("boot") received in an exchange, and the use of qualified intermediaries and reverse exchanges.
This document provides an overview of triple net lease (NNN) real estate investments. It defines NNN properties as those where the tenant is responsible for all operating expenses and management duties. NNN investments offer appealing features like income generation, capital appreciation, inflation protection, and positive cash flow from day one. High quality NNN deals involve strong locations, creditworthy tenants, and well-designed facilities. Common industries that utilize NNN leases include retail, restaurants, medical offices, and childcare facilities. The document also describes sale-leasebacks, build-to-suits, 1031 exchanges, and how NNN properties fit within exchange strategies.
This document provides a summary of an engineering tax services presentation. It discusses various tax strategies and incentives including cost segregation studies, energy tax credits under 179D and 45L, and the new IRS tangible property regulations. Cost segregation allows for accelerated depreciation by reclassifying portions of real property as personal property. Energy tax incentives provide deductions or credits for energy efficient commercial buildings. The presentation also reviews potential impacts of proposed Trump tax reforms and provides case studies on clients who benefited from these engineered tax strategies.
Marcus & Millichap / IPA Multifamily Forum: New England 2017 - Speaker SlidesRyan Slack
This document discusses several topics related to real estate development in Boston, including:
1) Mid-luxury multifamily developments between 10-15 stories that offer efficient floor plans and amenities at a price point between $850-$1200 per square foot.
2) Place-making approaches to designing public spaces that promote community health, happiness, and well-being.
3) A developer discusses how increasing building heights by one floor could increase units by 20% and discusses related feasibility considerations.
This document discusses emerging trends in real estate technology and their implications. It covers how technology is impacting the hotel industry through augmented and virtual reality for property research and major booking sites. It also discusses the growth of the Internet of Things and how real estate can leverage mobility data and the growing millennial workforce. Real estate investment and development trends incorporate new technologies like building automation, LED lighting, and virtual reality design collaboration.
Speaker Slides - Emerging Trends Summit Ryan Slack
This document discusses emerging macro trends in real estate, including experiential real estate focusing on amenities like art, dining options, and outdoor spaces. It also discusses workplace trends like increased employee mobility and underutilization of office space. Technology trends are discussed like augmented and virtual reality in hotels. Other trends mentioned include emphasis on wellness in workplaces with gyms and collaboration spaces over individual offices, as well as prevalence of mobile applications and internet of things devices. The growth of shared office spaces like WeWork across many US cities is also noted.
The document discusses the redevelopment of 180 Maiden Lane in New York City. It describes how the previous owner's stalled redevelopment plan was dramatically enhanced. A $50 million capital plan was implemented by MHP Project and Asset Management teams on a strict timeline. The transformative renovation of the base building and amenities was completed ahead of schedule and on budget.
New Trump Administration Updates: Federal, State and Local Energy & Specialt...Ryan Slack
This document summarizes a presentation by Michael F. D'Onofrio on various tax strategies including cost segregation, energy tax incentives, and changes to tangible property regulations. The presentation covers topics such as 179D energy tax deductions, cost segregation studies to accelerate depreciation, abandonment credits, and the new tangible property regulations. It provides examples of cost segregation results for a medical clinic and energy tax deductions for various property types such as offices and hotels. Learning objectives are also listed for topics like cost segregation, energy incentives, and the tangible property regulations.
Speaker Slides - RealInsight New York Multifamily SummitRyan Slack
This document discusses emerging trends in multifamily housing and innovations for the next housing cycle. It notes that amenities like larger fitness areas, lounges, and pet-friendly policies will be important. Technologies like smart home devices, property management systems, and sustainability features like co-generation and electric vehicle charging will also be valuable. Maintaining affordability through product type and neighborhood will be key. The document also summarizes perspectives from industry professionals on capital raising challenges but continued demand, pursuing off-market and distressed deals, structured returns, and partnering with sponsors.
Afternoon Keynote - Lindsay Eichner Kraus & Bruce EichnerRyan Slack
The document describes a new building project located at 45 East 22nd Street in New York City. It will be the tallest building in the Flatiron District at 777 feet tall and 65 stories, transforming the downtown skyline. The glass tower was designed by Kohn Peterson Fox and will contain 82 apartments and 230,000 square feet of space.
Increasing NOI & NAV with Smart Building Technologies & Intelligent DataRyan Slack
This document outlines various energy efficiency and sustainability projects that can be implemented at a multifamily property, along with their expected financial impacts. It lists 5 projects: 1) real-time energy monitoring and training, 2) LED lighting upgrades, 3) wireless controls, 4) combined heat and power, and 5) solar/battery storage. For each project it provides the estimated net operating income increase, capital expenditure, net asset value increase, and payback period. Implementing these projects could result in annual energy savings of $250,000 and increase the property's net asset value by $3.5 million.
The document discusses the benefits of exercise for mental health. Regular physical activity can help reduce anxiety and depression and improve mood and cognitive functioning. Exercise boosts blood flow, releases endorphins, and promotes changes in the brain which help enhance one's emotional well-being and mental clarity.
The document appears to be a presentation on the state of the New York City real estate market. It includes charts and data on the number of properties sold, total dollar volume, average price per square foot, and capitalization rates for Manhattan and the outer boroughs. There are also sections analyzing data for multifamily buildings as a whole, as well as broken down into elevator and walk-up buildings specifically.
Special Presentation - Christopher Ballard of UBER Southern CaliforniaRyan Slack
Uber is a ridesharing company that aims to provide reliable transportation everywhere for everyone. It operates in over 500 cities worldwide. Ridesharing is growing rapidly and is projected to account for 25% of all vehicle miles by 2030. Uber has partnered with various real estate developers, retailers, and municipalities to provide transportation solutions and promote their businesses. It sees continued growth and innovation in connecting communities through ridesharing.
Marcus & Millichap / IPA Multifamily Forum Southern California - Speaker SlidesRyan Slack
This document provides a summary of a presentation on the future of parking and transportation. It discusses trends showing that parking takes up a large amount of land in Los Angeles but cars are parked 96% of the time. Self-driving cars and shared mobility options may reduce parking needs. Studies show that actual parking demand at transit-oriented developments is lower than estimates. Shared mobility reduces private car ownership. Automated parking structures can use 40% less space and have other benefits. The presentation then discusses an adaptive garage concept and concludes with shared mobility trends.
National Multifamily Housing Council Presentation - Matthew Berger of NMHC Ryan Slack
The document discusses the timing and priorities for tax reform. It notes that passing a bill by the end of 2017 would be aggressive and Secretary Mnuchin sees August as not realistic. Key multifamily tax priorities include protecting flow-through entities and preserving deductions. Proposals from Republicans and Trump would lower rates but impact affordable housing without changes to protect programs like LIHTC. The outcomes of tax reform are unclear and will depend on issues of revenue neutrality, sunset provisions, and business provisions.
Marcus & Millichap / IPA Multifamily Forum Houston - Speaker SlidesRyan Slack
This document contains summaries of recent real estate financing deals, property tax rates in Houston and other Texas cities, strategies for boosting net operating income, and an overview of an opportunity to acquire and renovate the City West Apartments in Houston. It discusses the value-add opportunity at City West through renovations and operational improvements to increase occupancy and rents. The acquisition is seen as providing a 21.7% 5-year internal rate of return through revenue growth, expense reductions, and unit renovations to command higher rents.
NAIOP Golden Shovel Competition - Travis Duncan of Stanford UniversityRyan Slack
The Cardstone Group is proposing converting an existing industrial property into a makerspace through a phased redevelopment approach. They analyzed the property's highest and best use and determined a makerspace would increase the net present value by 25% to $124 million. Their proposal includes phasing 50% of the net leasable area to makerspace tenants by 2022, with financial projections showing increased net operating income and positive cash flows through 2030. The proposal aims to earn city support by diversifying jobs, reducing truck traffic, and improving public spaces, while an evergreen provision in the memorandum of understanding helps mitigate risk.
2016 NAIOP Golden Shovel Challenge - Jeffrey Bean of UC BerkeleyRyan Slack
The document discusses a proposed mixed-use development called Centennial Village on a 20-acre site in South San Francisco. The development would include 549 residential units and 351,000 square feet of office space. It provides details on the development timeline, revenue assumptions, costs, and projected returns. The proposed development aims to maximize the value of the site while maintaining existing relationships and features transit and trail access with the goal of creating a model for transit-oriented mixed-use development in the area.
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1. 1031 Exchanges –
The Art & Science of Capital Preservation
Presented by:
Citibank, N.A. – 1031 Exchange Service
David M. Gorenberg, Esquire
Certified Exchange Specialist®
Presented to:
2. Please Turn Cell Phones and Pagers to Silent or Off.
Thank you.
2 1031 Exchanges: The Art & Science of Capital Preservation
3. Important Disclosures
This presentation does not constitute legal or tax advice. Citibank and its employees do not provide tax or
legal advice and are not responsible for advising customers on the laws or regulations pertaining to any
1031 exchange transaction. Citibank and its employees will not make any representations regarding the
tax consequences of any 1031 exchange transaction. It is the customer’s responsibility to seek tax and
legal advisors in connection with any 1031 exchange transaction.
IRS Circular 230 Disclosure: To the extent that this material or any attachment concerns tax matters, it is
not intended to be used and cannot be used by a taxpayer for the purpose of avoiding penalties that may
be imposed by law.
Citibank, N.A., Member FDIC. Citibank and Arc Design is a registered trademark of Citigroup Inc.
3 1031 Exchanges: The Art & Science of Capital Preservation
4. Overview of the Statute and Regulations
4 1031 Exchanges: The Art & Science of Capital Preservation
5. Taxation 101
• Generally, all income is taxable,
unless specifically exempted by law.
• Even illegal income, such as stolen
or embezzled funds, must be
reported on Line 21 of Form 1040.
Source: Department of Treasury, Internal Revenue
Service, Publication 525.
5 1031 Exchanges: The Art & Science of Capital Preservation
6. IRC Section 1031
• “No gain or loss shall be recognized on the exchange of
property held for productive use in a trade or business or
for investment if such property is exchanged solely for
property of like kind which is to be held for productive use
in a trade or business or for investment.”
• §1031 provides for deferral of taxes,
not complete elimination.
6 1031 Exchanges: The Art & Science of Capital Preservation
7. Like-kind Property
Foreign real property is not like-kind to U.S. real property.
7 1031 Exchanges: The Art & Science of Capital Preservation
8. Business or Investment Use
• There are five tax classes of property:
1) property used in taxpayer’s trade or business;
2) property held primarily for sale to customers;
3) property which is used as your principal residence;
4) property held for investment; and
5) property used as a vacation home
• Section 1031 applies to the first and fourth
categories (and perhaps the fifth)
8 1031 Exchanges: The Art & Science of Capital Preservation
9. Less than Fee Interests in Real Property that Qualify for
Exchanges
• Leases with at least 30 years remaining, including renewal options
• Vendee’s interest in a land sale contract; not the vendor’s interest
• Undivided interest in one property for an undivided or 100% interest in
another property
• Remainder interest in real property
• Timber rights, riparian rights,
mineral rights
– As determined by state law
9 1031 Exchanges: The Art & Science of Capital Preservation
10. Like Kind Personal Property
• Under the regulations, personal depreciable property
used in business or held for investment is exchanged
with like-kind property if exchanged either for property of
a like kind or like class
• Properties are of like class if they are in the same:
– General Asset Class – Rev. Proc. 87-56, or
– Product Class – SIC Manual (4 digits)
• Personal property is like kind if identical
10 1031 Exchanges: The Art & Science of Capital Preservation
11. Like Kind Personal Property
• Livestock of the same sex
• Automobiles for automobiles
• Buses for buses
• Manufacturing equipment for manufacturing equipment
• 13 general asset classes; OMB Standard Industrial Classification (SIC)
Manual identifies 4-digit product classes; New North American Industry
Classification System (NAICS) is 1400 pages
– Exchanges within product class
11 1031 Exchanges: The Art & Science of Capital Preservation
12. Common Personal Property Exchanges
• Aircraft
• Artwork
• Collectibles
• Equipment
• Fleet Vehicles
• Intellectual Property
– Licenses, Franchises, Patents, Trademarks
• Others
12 1031 Exchanges: The Art & Science of Capital Preservation
13. §1031 in a Nutshell
• To obtain complete deferral of capital gains taxes, the
taxpayer should:
– Purchase replacement property that is equal or greater in value to
the relinquished property
– Have equal or greater equity in the
replacement property
– Have equal or greater debt on the
replacement property
– Receive nothing except like-kind property
– Avoid constructive receipt of exchange
proceeds
– Use a qualified intermediary
13 1031 Exchanges: The Art & Science of Capital Preservation
14. Why Exchange?
14 1031 Exchanges: The Art & Science of Capital Preservation
15. Delayed Exchanges
- Statutory Requirements
• 1984 Congress amends Section 1031
– 45 day identification period
– 180 day exchange period runs concurrent
• Or due date of tax return, whichever is earlier
– Calendar days, not business days
– No extensions
– Exchange starts on date of recording, or when burdens and
benefits of ownership of relinquished property are transferred,
whichever is first
15 1031 Exchanges: The Art & Science of Capital Preservation
16. Identification Requirements
• Signed, and in writing
• Delivered
– QI or seller of replacement property
• Unambiguously described
– Legal description
– Street address
– Distinguishable name (e.g., Mayfair Apartment Building)
• May be revoked or amended, with same formality as above
16 1031 Exchanges: The Art & Science of Capital Preservation
17. Identification Rules
• 3 Property Rule – up to 3 properties, without regard to FMV;
or
• 200% Rule – any number of properties, so long as aggregate FMV
does not exceed 200% of FMV of relinquished properties;
but
• 95% Exception – if first two rules violated, must acquire 95% of FMV
of all identified properties
17 1031 Exchanges: The Art & Science of Capital Preservation
18. Time Restrictions
Identification
Period
Exchange
Period
Day 0 Day 45 Day 180
NOTE: The total exchange period cannot exceed 180
days, under any circumstances.
1031 Exchanges: The Art & Science of Capital Preservation
18
19. Regulations: 1.1031
- safe harbors
• 1.1031(k)-1(g)
– (2) Security or Guarantee Arrangements
• Determination of whether the taxpayer is in actual or constructive receipt of the exchange
funds is made without regard to existence of mortgage, standby letter of credit, third party
guarantee, etc.
– (3) Qualified Escrow Accounts and Qualified Trusts
• Determination of whether the taxpayer is in actual or constructive receipt of the exchange
funds is made without regard to whether the funds are held in a Qualified Escrow Account or
Qualified Trust
– QEA – Escrow holder is not a disqualified person; escrow agreement contains “(g)(6)” limitations
– QT – Trustee is not a disqualified person; trust agreement contains “(g)(6)” limitations
– (4) Qualified Intermediary
– QI is not considered an agent of the taxpayer; is not a disqualified person; QI enters into “exchange
agreement” that contains the “(g)(6)” limitations
– (5) Interest and Growth Factors
• Determination of whether the taxpayer is in actual or constructive receipt of exchange funds is
made without regard to the fact that the taxpayer is or may be entitled to receive any interest
or growth factor with respect to the deferred exchange.
1031 Exchanges: The Art & Science of Capital Preservation
19
20. Regulations: 1.1031
- (g)(6) Limitations
• (i) An agreement limits a taxpayer's rights as provided in this paragraph (g)(6) only if the
agreement provides that the taxpayer has no rights, except as provided in paragraphs
(g)(6)(ii) and (g)(6)(iii) of this section, to receive, pledge, borrow, or otherwise obtain
the benefits of money or other property before the end of the exchange period.
• (ii) The agreement may provide that if the taxpayer has not identified replacement
property by the end of the identification period, the taxpayer may have rights to receive,
pledge, borrow, or otherwise obtain the benefits of money or other property at any time
after the end of the identification period.
• (iii) The agreement may provide that if the taxpayer has identified replacement property,
the taxpayer may have rights to receive, pledge, borrow, or otherwise obtain the benefits
of money or other property upon or after
– (A) The receipt by the taxpayer of all of the replacement property to which the
taxpayer is entitled under the exchange agreement, or
– (B) The occurrence after the end of the identification period of a material and
substantial contingency that –
• (1) Relates to the deferred exchange,
• (2) Is provided for in writing, and
• (3) Is beyond the control of the taxpayer and of any disqualified person (as
defined in paragraph (k) of this section), other than the person obligated to
transfer the replacement property to the taxpayer.
1031 Exchanges: The Art & Science of Capital Preservation
20
21. Treasury Inspector General for
Tax Administration
21 1031 Exchanges: The Art & Science of Capital Preservation
22. Treasury Inspector General for Tax Administration
• Reference 2008-30-154; August 27, 2008
– “Guidance Could Be Enhanced for Deciding to Use a Qualified
Intermediary in Like-Kind Exchanges”
• “This report presents the results of our review of qualified intermediary
regulations and qualification requirements. The objectives of this review
were to examine transactions subject to Internal Revenue Code Section
1031, assess the qualification requirements for qualified intermediaries,
and determine the legal protections available to taxpayers. We
conducted this review in response to a request by the Chairman of the
United States House of Representatives Committee on Financial
Services.”
1031 Exchanges: The Art & Science of Capital Preservation
22
24. Treasury decision 9413
- Regulations Update
• Designated settlement funds – escrow accounts, trusts, and funds used
in deferred like-kind exchanges; loans to exchange facilitators.
• “468-B” Regulations – The regulations provide rules regarding the
taxation of income earned on escrow accounts, trusts, and other funds
used during deferred like-kind exchanges of property
• “7872” Regulations - regarding below-market loans to facilitators of
these exchanges.
• Effective for all transactions commenced on or after October 8, 2008.
1031 Exchanges: The Art & Science of Capital Preservation
24
25. 468-B Regulations
• IF:
– The exchange funds are $2,000,000 or greater; OR
– The exchange funds remain with the QI for 6 months or longer
• THEN:
– All interest earned on the exchange funds must be paid to the
taxpayer
• Applicable Federal Rate
• 91-day (13-week) T-Bill rate
1031 Exchanges: The Art & Science of Capital Preservation
25
26. Effect of Bankruptcy of Large National
Qualified Intermediaries
1031 Exchanges: The Art & Science of Capital Preservation
26
27. QI Bankruptcy
- A Tale of Two Cities
• Southwest Exchange
– Henderson, NV; Donald K. McGhan and others in his family
– 2007; 130+ clients; $97.5MM+
– Funds used to acquire breast implant company, 19-passenger jet,
lavish meals, etc.
27 1031 Exchanges: The Art & Science of Capital Preservation
28. QI Bankruptcy
- A Tale of Two Cities
• 1031 Tax Group
– Richmond, VA; Edward H. Okun and others in his business
– 2007; 300 +/- open exchanges; $151MM+
– Funds used to acquire jewelry, sports cars, helicopters, shopping
malls and other “toys”
28 1031 Exchanges: The Art & Science of Capital Preservation
29. QI Bankruptcy
- The LandAmerica saga
• Millard refrigerated Services v. LandAmerica
– http://www.les1031creditorcommittee.com/76_3147.pdf
– DeGroot v. Exchanged Titles
• 159 B.R. 303 (1993)
– Cook v. Garcia
• 110 F.3d 67 , 1997 WL 143827 (1997)
– In re San Diego Realty Exchange Co., Inc.
• 24 F.3d 249, 1994 WL 161646 (1994)
– Cook v. 1031 Exchange Corp.
• 29 Va. Cir. 302, Not Reported in S.E.2d, 1992 WL 885015 (1992)
– In re. Sale Guaranty Corp.
• 220 B.R. 660 (1998)
– Rechtzigel v. Fidelity National
• 748 N.W. 2d 312 (2008)
1031 Exchanges: The Art & Science of Capital Preservation
29
30. State Regulation of Qualified Intermediaries
• Enacted • Pending
– California – Arizona
– Colorado – Maine
– Idaho – Oklahoma
– Nevada – Oregon
– Virginia – Texas
– Washington
1031 Exchanges: The Art & Science of Capital Preservation
30
31. Other Considerations
1031 Exchanges: The Art & Science of Capital Preservation
31
32. Choosing a Qualified Intermediary
• Phone Book? • Qualifications
– When was firm established
• Internet?
– Primary business, or sideline
• Referrals – How many transactions
completed
– Financial stability
– Security of exchange proceeds
– Fees, and what is included
– FEA
• www.1031.org
– Certified Exchange Specialist®
• www.1031ces.org
1031 Exchanges: The Art & Science of Capital Preservation
32
33. Contact Information
David Gorenberg, Esquire Kristina C. Harshany
Certified Exchange Specialist® Certified Exchange Specialist®
Senior Vice President, 1031 Exchange Services Vice President, 1031 Exchange Services
Citibank, N.A. Citibank, N.A.
1650 Market Street, Suite 3550 1650 Market Street, Suite 3550
Philadelphia, PA 19103 Philadelphia, PA 19103
Office: 267.385.3624 Office: 267.385.3625
Fax: 866.767.8201 Fax: 866.765.8874
Mobile: 610.883.2181 Mobile: 610.883.2181
E-mail: david.gorenberg@citi.com E-mail: kristina.c.harshany@citi.com
33 1031 Exchanges: The Art & Science of Capital Preservation