Simon's Hostile Tender for Taubman

Why? The owners capitalized and amortized 50 percent of the purchase price ($12 million) simply because the tax rules allowed it; therefore the

Under Canadian Tax Law, there is an election for companies to defer recaptures and capital gains of property that was involuntarily or voluntarily disposed of. In this research paper, we attempt to prove that the election is a useful taxation strategy for businesses so that they are not subject to pay taxes on capital gains or recaptures until such a time where they may acquire an eligible replacement property that will help them earn business income. We will provide facts, definitions, and examples to illustrate the use of this election throughout the paper by explaining the capital cost allowance system, the offset available to business for capital gains and recaptures, the election process, the rules regarding replacing former business

Because this is the case, the Net Income effect of this decision has be the biggest factor to consider and an operating lease structure would therefore appeal to investors the most.

However, on the flip side, the price offered by RSC and TCV consortium was $6, which was significantly higher than the first three rounds of financing (tranches A,B and C) at

The Tax Court, per Judge Ruwe, issued an order on May 8, 1995, denying Pope & Talbot 's motion and granting the IRS 's motion. The court 's opinion characterized the issue before it as one of "first impression," and found resort to the legislative history of the statute necessary since the court was unable to "achieve...certainty based on the language of the statute." After reviewing the legislative history of IRC Sec. 311, the court observed the following: It is apparent that the purpose underlying IRC Sec. 311(d) was to tax the appreciation in value that occurred while the corporation held the property and to prevent a corporation from avoiding tax on the inherent gain by distributing such property to its shareholders...It follows that we must focus on the value of the Washington properties as owned by petitioner and value them as if petitioner had sold them at fair market value at the time of distribution.

John and Jane own and rent out a duplex in Atlanta. They are getting older now and are planning to retire and to move to Miami. John and Jane would like to sell the Atlanta Duplex and purchase a small commercial building next to the lovely condo they bought on the beach. The main issue is John and Jane can only afford to buy this building if they are able to capture all of the existing equity in their Atlanta duplex. To avoid (defer) a taxable event when they sell their duplex John and Jane can utilize Section 1031 of the IRC. There are, however, a few hoops that John and Jane must jump through to qualify.

Wanting to gain experience in the real estate field, Edward Alexander is looking to invest into a small income-producing apartment in the Back Bay-Beacon Hill area of Boston. He considers paying rent to someone else a waste of a capital building opportunity, given that he is building someone else’s equity.

Table 7 in the detailed analysis above shows the summary of the Discounted Cash Flow analysis performed for each of the four potential properties considered for investment. From the chart below, we observe that of the four properties, TFB has the maximum increase in reversion value at the end of the holding period, i.e. 10years. On a primarily income generation potential basis, Alison Green, with a Net Present value of the future rents at $734.29 looks attractive among the four options. Looking at the Investment ranks of the four properties with Simple returns and Discounted returns variables, Alison

Angus Cartwright III, an investment advisor, was asked to provide investment advisory services for two clients, John DeRight and Judy DeRight. They both wanted to purchase a property that (1) is large enough to attract the interest of a professional real estate management company and (2) has a minimum leveraged return on their investments of 12% after

After analysis of Mr. Alexander’s proposal, it is obvious why he should take advantage of a real estate investment opportunity. The experience he would gain coupled with the added income would establish a solid foundation for making more investments in the future. To this end, however, I find Alexander’s plan for the Revere Street property falls short. A major deficiency is that his projections are almost entirely predicated on estimates and assumptions that are neither conservative nor reliable. In a similar vein, Alexander’s “DIY” approach is not only exemplar of naiveté, but also suggestive of many implications that were overlooked in his proposal. And, even more discouraging, a best-case scenario analysis reveals that even without

The report presents a case about AMB, which is a leading pension real estate advisory firm that has recently proposed to turn itself into a publicly traded Real Estate Investment Trust (REITs) and is planning to persuade its client to contribute their real estate assets to create a new REIT. Furthermore, the report also includes considerations of Anne Shea, who is the Assistant Vice President at Curator’s Fund; which is considering exchanging her shares in the commingled fund for the shares in the REIT.

BACKGROUND: Sue Growne, client G14159, is looking to purchase a tavern, which would include both realty and personality. So ReaLand CPA’s could better serve this client, I, Bobbi Paternico was tasked with researching the legal and tax options available to the client, based upon the entity utilized for the purchase and the method of purchase.

Premiums associated with tender offers, as measured against stock prices one day or one week prior to the offer announcement, would be affected by information leakage and the extent to which a company was viewed as “in play” by the arbitrage community. And the issue of fairness would seem to depend more on the absolute, not relative, degree to which the Rales brothers’ bid exceeded the current stock price. See exhibits 3 and 4. Do you think analysis in Exhibit 10 justifies rejecting the bid?

Within its franchising system, the company provides retailing strategy and marketing techniques in turn for receiving the franchisees fees that are based on sales. Harvey Norman is said to be ‘part retailer, part property-trust’ as the company property holdings account for nearly 50 percent of its total assets (Money manager, 2008). These assets also produce main source of income for the company including regular rental income from the franchisees, and also acting as an investment income where it can successfully develop properties from vacant land to retail complexes. The major benefits of this integrated model enable Harvey Norman to lower the cost of debt financing by securitizing a portion of income-producing property portfolio. This would free up capital and helps to boost returns.

The offer had been agreed upon from both parties is important. The acceptance of an offer cannot alter the terms of the specified in the offer. “An offeree accepts by saying or doing something that a reasonable person would understand to mean that he definitely wants to take the offer.” (Beatty, 2016) Once the buyers or offeree came to an