Articles

MWE written articles.

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New Regulations Offer Rare Tax Boon for Real Estate Businesses

New IRS regulations offer real estate owners, operators and developers a new way to save money related to repairs and dispositions of structural improvements. The pro-taxpayer regulations address the age-old question of whether owners can write off previously capitalized improvements that were abandoned, demolished and/or replaced. They also address long-debated gray areas of real estate…

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Use of Options in Real Estate Transactions

by: Mike Rosenberg, CPA, Retired Partner as published in MANN Report Options can be used in real estate transactions to accomplish a number of important tax and financial objectives, including deferring the recognition of income without deferring the receipt of cash. In situations where the potential for future appreciation of a property is speculative, options…

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Planning a Like-Kind Exchange of a Leasehold Interest in Real Estate

by: Mike Rosenberg, CPA, Retired Partner   The tax and financial benefits of like-kind exchanges of real estate are well known to property owners. A properly structured like-kind exchange allows a seller of property to defer gain recognition on the sale of and invest pre-tax dollars into a larger portfolio of assets. Among the various requirements…

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Tax Savings Associated With Repositioning, Retrofitting And Greening Of Properties

As real estate owners and operators reposition and retrofit their properties, most are focusing on environmentally conscious upgrades including upgrades to the lighting and mechanical systems as well as the building envelope. Although the costs associated with the upgrades may be significant, the anticipated utility cost savings should reduce the “payback” period and, as a…

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Introducing the New User-Friendly K-1 for Hedge Fund of Funds

You have invested in an “Alternative Investment”. It is a hedge fund of funds. The partnership in which you invested has in turn invested in 20 or 30 other hedge funds in order to diversify over different strategies and asset classes and minimize risk. Your hedge fund is required to aggregate all items of income…

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Structuring a Hedge Fund: Which Option is Right for You?

by: Jeffrey Tunkel, Retired Partner   Investment managers seeking to start hedge funds, both domestic and offshore, have several options available to them in structuring the funds. The most common structures are side-by-side, master-feeder and mini-master. Side-by-Side Structure In a side-by-side structure (see diagram A) there is both a domestic fund and an offshore fund…

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Planning Ahead with a Like-Kind Exchange in Anticipation of Foreclosure

by: Mike Rosenberg, CPA, Retired Partner Distressed properties are working their way through the workout and foreclosure process. In certain deals, owners of commercial and residential properties with distressed debt will find ways to restructure the debt. In others, a foreclosure is inevitable. If the debtor owns property subject to nonrecourse loan that is in…

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Benefits of Self-Cancelling Installment Notes on Intra-Family Sales

by: Mike Rosenberg, CPA, Retired Partner An installment sale of property involves a cash down payment and an installment note issued for the balance of the purchase price. Intra-family installment sales offer significant estate planning benefits, particularly in a low interest rate environment and lower property values. Such a sale, using a small cash down…

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Business, Succession, Gift & Estate Planning for Family Businesses

by: Mike Rosenberg, CPA, Retired Partner Business owners confront the same succession and estate planning issues faced by other entrepreneurs. These issues focus on how family businesses, their founders, successors, employees and heirs achieve their personal and financial objectives. These enterprises can either survive and thrive or falter and fail – depending upon their ability…

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Expenditure Structuring in Connection with Tenant Leases

Unemployment and underemployment rates have increased (although now relatively stable), certain tenants are downsizing and need less space, vacancies have increased, rents have decreased and more sublease space is on the market. All of these factors, when combined with increasing cap rates and general uncertainty, have contributed to a precipitous drop in real estate values.…

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