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Leveraged Reverse Freezes
Traditionally, a reverse freeze has been strategy that has been used to manage and transfer wealth between a limited partnership (“LP”) or a limited liability company (“LLC”) that is composed of both preferred and common interests. A reverse freeze is established in a way that makes the partnership interest the preferred interest. Preference returns are paid to the preferred partnership (“PP”) and are senior to all common partnership (“CP”) distributions.
A leveraged reverse freeze is a configuration of a traditional reverse freeze. In a leveraged reverse freeze, a preferred partnership interest is exchanged for either a note, transfer of preferred partnership interest to a designated grantor retained annuity trust (GRAT), or other types of real estate planning means. Interest payments on such vehicles are typically paid at the applicable federal rate (“AFR”) or the Internal Revenue Code Section 7520 rate.
Under most circumstances, the seller of the preferred partnership interest maintains the common partnership interest. The end goal of a leveraged reverse freeze is for the receiving family member or GRAT to receive a portion of the cash flow and appreciation after all interest payments/GRAT annuity payments have been accounted for. In order for a leveraged reverse freeze to be successful, it is critical for the preference rate, which is part of the preferred partnership, required to preserve the face value to be much greater than the applicable federal rate or the Section 7520 rate.
Federal Appraisal LLC offers several important services for those creating leveraged reverse freezes including, but not limited to:
Acting as a consultant to the estate planner regarding the structure of the partnership
Determining the appropriate preference rate to the preferred partnership interest
Determining the percentage of preferred partnership interests
Calculating the Fair Market Value (“FMV”) of the common partnership interests
Interested candidates of a reverse freeze, leveraged reverse freeze, or a vast array of other appraisal services can visit federalappraisal.com or email mark@federalappraisal.com
A house amidst a large, well-manicured grassy field
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Investors and Property Managers
Each investor has its own unique business requirements. That’s why Federal Appraisal, LLC was formed. Many of the appraisal and consulting needs of investors can only be solved with complex and non traditional appraisal and consulting services. Federal Appraisal specializes in those services. We understand that each investor requires different analyses and reporting. We tailor each of our engagements to the needs of the individual investor and to those investing in the investors.
Institutional and Private Investors
REITS
Insurance Companies, Pension Funds
A sampling of the services other to investors follows:
portfolio and single asset appraisals
acquisition and disposition support
portfolio analysis and strategy
real estate department management review
advisor compliance reviews
property manager compliance reviews
market studies and research
feasibility studies
development analysis
net lease analysis
appraisal process reviews
workouts and restructurings
internal and external appraisal reviews
appraisal policies and procedures reviews
appraisal management and appraisal department outsourcing
expedited services for time-sensitive projects
reconciliation services for conflicting valuation opinions
underwriting analyses
See our services for Accounting and Legal issues pages, for more information on Federal Appraisal.
Management Consulting Issues and Solutions for Investors
Federal Appraisal provides user-defined scopes of services and agreed upon procedures services relating to investors.
Securities and Exchange Commission (SEC)
Federal Appraisal, LLC provides the real estate appraisals and valuation reporting support required by the SEC. See our SEC page for more information.
Internal Revenue Service (IRS)
Federal Appraisal, LLC provides the real estate appraisals and valuation reporting support required by the IRS. See our IRS page for more information.
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Corporations and Businesses, Large and Small
Today, companies of all sizes can turn to Federal Appraisal LLC for all their appraisal and consulting services. Federal Appraisal services large, small, and mid-sized companies, accounting firms, law firms, corporate real estate groups, private and public investors, developers, and management companies.
Federal Appraisal LLC also services private owners.
We provide the highest level of service, while we fully recognize the special needs of small and mid-sized companies to control costs. It is precisely because of this need that Federal Appraisal was created. Our firm was organized specifically to control the costs of our services, and still maintain the highest quality of professional service. Our business model enables us to offer competitively priced services, over a greater geographic area and covering a greater number of issues, than most national appraisal firms, including local market issues and expertise.
Business Appraisal / Valuation
Real Estate Appraisal
General Services for Corporations
Going Concern
Damages and Lost Income
Good Will & Intangibles
Mark to Market
Liquidation
Real Property Valuation
A Special Note to Small And Mid-sized Companies
Now that you know that such services are available to your small and mid-sized company, we hope that you agree that prudent management dictates the use of such services. Real estate often represents the single largest investment for a company. The consequences of a bad real estate investment, acquisition, or lease can be fatal to a small or mid-sized company.
Companies that lease their real estate are not immune to the fatal consequences of bad real estate decisions. While the cash out lay for lease in any given year may not appear significant, the total cash outlay for any longer-term lease (seven years or longer) often exceeds purchase price of real estate. Furthermore, the terms of the lease (base rent, rent step ups, rent escalations, operating expense pass-throughs, real estate tax pass-throughs, utility expense pass-throughs, and other terms) can make the analysis of the lease substantially more complicated and difficult than the analysis of the sale.
See our Lease Analysis and Audit page and our Corporate Real Estate page for more information.
Similarly, consultants and managers who advise poorly assume liability. Unfortunately, small, and mid-sized companies can rarely afford to employee real estate appraisal and consulting professionals. Federal Appraisal LLC eliminates the liability by supplying the services necessary to properly advise clients. Federal Appraisal is able to work with consultants and managers in either a joint venture or a subcontractor capacity.
Management Consulting Issues and Solutions for Small And Mid-sized Companies
Federal Appraisal provides user-defined scopes of services and agreed upon procedures services relating to large, small, and mid-sized companies.
Securities and Exchange Commission (SEC)
Federal Appraisal LLC provides the real estate and business appraisals and valuation reporting support required by the SEC. See our SEC page for more information.
Internal Revenue Service (IRS)
Federal Appraisal LLC provides the real estate and business appraisals and valuation reporting support required by the IRS. See our IRS page for more information.
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Government Services
Appraisal and appraisal consulting requirements vary significantly from government agency to government agency. While the variances are often simple, the failure to meet the requirements can lead to a critical non-compliance. The noncompliance may be non-recoverable and often cost thousands of dollars but could cost tens to hundreds of thousands of dollars. Federal Appraisal offers expert appraisal and appraisal consulting services for many of the major government agencies.
IRS
The Internal Revenue Service (IRS) and the courts that hear its cases prescribe their own appraisal practices and procedures. While the appraisal theory behind IRS appraisals is mostly the same as any other appraisal, failure to comply with IRS specific procedures can result in the disqualification of an appraisal and a loss of essential support for a tax stance.
Federal Appraisal, LLC provides IRS appraisals for both taxpayers and the IRS.
Federal Appraisal, LLC provides numerous services to assist property owners in managing the various tax and audit issues that impact real and personal property.
See our IRS page, as well as our accountants page and our attorneys page.
HUD
The Federal Housing and Urban Development Agency (HUD) prescribes its own appraisal procedures and its own appraisal formats. While the appraisal theory behind the HUD appraisals is the same as any other appraisal, failure to comply with HUD’s own procedures and formats can result in the disqualification of an appraisal.
See our HUD page.
Property Tax Assessment and Appeals
There are numerous occasions where the value of a property is related to taxes. Each taxing situation requires special appraisal and consulting considerations. The considerations might be a specialized appraisal for cost segregation, depreciation, and income tax. Another might be an explanation and justification for a divergence from the purchase price basis for a transfer or gains tax calculation. Others pertain to tax position, basis, or feasibility, as with impairments, structured leases, barter agreements, gifts, and estates.
Each taxing situation requires appraisal and consulting experience in order to maximize taxing goals. Federal Appraisal, LLC specializes in providing appraisals for tax issues.
GSA
The General Services Administration of the federal government handles the real estate acquisition and leasing for most of the federal agencies. They have special biding, contracting, and reporting requirements. While the requirements are easy enough to meet, the mismanagement of the requirements could add substantial delays to a project.
SEC & Investor Relations
Federal Appraisal, LLC can provide any of the real estate appraisals and valuation reporting support required by the Securities and Exchange Commission (SEC). Whether its SEC reporting requirements to compliance with the appropriate accounting, tax, and audit reporting procedures, or it’s a special issue reporting requirement, Federal Appraisal, LLC can help.
Mark to Market
Federal Appraisal, LLC provides “Mark to Market” Appraisal Services as required by the Government Accounting Standards Board (“GASB”) new rule, Statement 52. The rule requires state and local government endowment funds that hold land and other real estate as investments to report the asset or liability at fair value beginning next year. When real estate is marked to market, for accounting purposes it is assigned the value that it would fetch in the open market. Currently, governments report such assets and liabilities at historical cost.
See our Mark to Market page.
See our Business Appraisal and Valuation and our Property Type pages for more
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