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Consoldidated
Reverse Management, Inc. ("CRM") provides "non-safe"
harbor exchange services for investors whose transactions fall outside
the "safe harbor" guidelines issued by the IRS last year
(in Rev. Proc 2000-37). When it is not possible to sell the relinquished
property or finish construction in a build-to-suit situation within
180-days, then the transaction will not fall within the IRS safe
harbor rules. CRM provides the services necessary to qualify the
transaction as a tax-deferred exchange.
In those instances
where a property owner cannot meet the 180 day IRS "safe harbor"
restrictions but still wants a "replacement property"
to qualify in its transaction as a valid tax-deferred exchange,
CRM can take title to the replacement property, build the required
improvements and when the improvements are completed, transfer it
back to the taxpayer in exchange for its sale of relinquished property.
CRM's services also include investing equity in the property, having
a more significant involvement in the ownership of the parked property
and supervising the construction of improvements to the property.
These "non-safe" harbor transactions are much more complex
than "regular" exchanges and require customized solutions
to fit the particular circumstances of the exchange. In order for
CRM's activities not to be characterized as acts of the taxpayer's
agent, CRM must have sufficient "benefits and burdens"
of ownership; this is a test which is determined on a case-by-case
basis. If your reverse exchange includes construction or non-safe
harbor issues, we will be glad to discuss the various ways CRM can
work with you to resolve them.
Consolidated
Reverse Management, Inc. ("CRM") is an affiliate of Reverse
Exchange Services, Inc. ("RES").
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