lunco: It's much too complicated for here and I am not a tax expert. I suggest you consult with an estate tax expert (not just an attorney, banker or cpa.....a specialist in estate tax) about the risks you are taking by retaining control of the LLC. You might be risking having the entire LLC included in your gross estate.
Also, if you have been selling depreciable property to the LLC, you have an issue which can be overcome with installment sale qualification (section 453) and have a real problem with section 1239....ordinary income from sale of depreciable property to a related entity. I repeat, I am not expert in the area, but I have been involved with so many transactions I have learned from experts how much I don't know about the tax system. If your current tax advisor has not alerted you to these issues, I suggest a cpa specializing in tax.....not accounting...not auditing, not computer consulting...find one who does nothing but tax. They do exist, but not in small cpa firms.
The cumulative effect of annual gifts over a long enough period of time is never "inconsequential". It may be small relative to the total estate, but never inconsequential. Give away 1 million and save 450,000 of estate taxes pays a helluva lot of estate planning fees.
Sorry to rain on your parade, BUT, it looks like you are describing a qualified joint interest. In such a case only half the property gets a step up in basis with the first death.
Been giving the kids the annual gift tax exclusion limit (from 40,000 from 2 donors to 2 donees to 56,000 today) for years and years except 2008. Never underestimate the power of the annual exclusion over many years. Flip gains pay for it resulting in no decrease in the taxable estate.
Am considering a defective grantor trust (where I pay income taxes) for the kids or an irrevocable trust which is not defective since both kids are under the Obama surtax thresholds, at least for now. In either case, I don't have much low gain assets to give. Am considering more margin debt to give cash. Hard to pick which is best because all depend on future events and tax rates and all are irrevocable. Gotta be well thought out because once done, it's done forever.
If the above does not answer your question, it's because the answer is none of your business.
Splendid for yield. Hamo has told the world he does not expect the price to go up much if at all in the next 6 months. Growing aggregate cad is not a problem. Griffin will do this in a big way. Growing cad PER SHARE is the challenge. Excluding what is done with the current offering, we are looking at 40 cents per quarter through 2015. Consequently, I don't see much price appreciation without Hamo doing something to lower the yield, like the next spinoff.
For tax deferred yield, buy NRF.
For price appreciation, buy NSAM. It may take until after spoonfeeding in Nov., but it will come.
At the cost of federal and Rhode Island estate taxes.
For those without death tax exposure, having appreciated property included in the gross estate (whether or not owned) is a no-brainer. For those with only a state death tax to worry about, it's a calculation of the state death tax cost vs the income tax savings. For those facing both federal and state death taxes, gifts of appreciated property are likely to result in less overall tax to the family than dying with the property.
Those with lesser wealth don't have to worry about death taxes but they do have to worry about a nursing home taking all their assets before Medicaid steps in. Here, the gift of appreciated property can preserve assets for the kids provided the lookback period (currently 5 years) is met. The cost is carryover basis resulting in income taxes.
But most families I have talked to about this would rather pay a 25 to 30% income tax than a 100% nursing home tax.
NRF....4.431 at 8/29 settlement vs 4.849 at 8/15....down 418K.
NSAM....1.756 at 8/29 vs 1.685 at 8/15......up 71K.
Of course nrf above does not include DB borrowing 30 million for the offering. That will show in next report.
That's what happens with growing equity reits. The depreciation from new properties offsets increasing rents and declining depreciation on the older properties. The tax deferral becomes permanent as long as sufficient growth continues.
Good for you. To get the most mileage out of small dollars, take the spouse/friend out to dinner and tell them Sun Communities is paying for it. They love it so much maybe you get lucky after dinner.
Raised 507.0 thru 9/11 vs 444.4 thru 8/14 in sup 9. Thus, 62.6 million in 28 days, an average of 2.236 per day.
Not as good as the 3.76 million per day raised in the 20 days starting with 7/26 thru 8/14, but better than the 1.925 per day for 28 days between 6/27 and 7/25.
Last report from Income 2 was thru 8/11, so it's harder to estimate the quarter. Nevertheless, it looks to me like 250 for the quarter, continuing a 50 million per quarter increase. If so, by quarter, 150 +200+250 = 600 thru 9/30.
Raise 300 in 4Q = 900 for year without the rxr startup vs 800 still in nsam budget in Aug slides.
2 billion RXR registration should be declared effective shortly so they can begin selling in 4Q. Won't be lotsa dollars in 4Q. Important thing is to be out of the start gate before 2015.
For years I have been a yield investor. Still am, BUT current dividends are now so much more than what we spend AND I am losing the battle to keep my AGI below the Obama extra taxes threshold, I don't mind having some low yield growth stock in the portfolio. If I were to switch some NSAM to NRF, it would be in the IRAs because the gains in the taxable account are too big.
Equity reits getting creamed today also. VNQ down over 2%. SUI down over 3%, so I bought two flip lots. Divi probably announced next week and go ex around 9/25....65 cents. SUI yield now over 5%. Grab it while you can at under 52 which is where 2.60 = exactly 5%. Div will be raised next april 3 cents or so..
HCN offering 15.5 million shares at 63.75.....a whopping 4.1% discount to yesterday's 66.49 closing price.
After hours yesterday closed at 64.00, off 3.7%. Premarket trading over 64, a sign pricing too low.
I will buy under 63.60. Otherwise I will pass because yield too low. 3.18 / 64 = 4.97%. I'd rather buy more SUI and certainly more NRF if I were not already way overloaded.
Correct. And since my lowest basis shares were purchased in 2012, the gain is long term capital gain, taxed the same as qualified dividends (which reits almost never pay). I'm happy to trade nonqualified dividends for long term capital gains.
I think it is ALL roc for several years to come. Unfortunately I'm running out of basis with some early shares.
My lowest basis lot was 3.95 at the end of 2013. Subtract 1.90 for this year leaves 2.05 going into 2015. If the 2015 dividend is 1.60 (which I think it will be), this lot has 45 cents left.
Before this buying spree began Larrea owned 249,367 shares, mostly purchased in the fall 2008 and spring 2009, at the same time Grupo was loading up on dirt cheap shares.
Beginning on 7/30/14 thru 9/10/14, he has purchased in the open market 770,000 shares at an eyeball average of 32 per share......about 24.6 million. After the 9/10 purchase of 50,000 he owned 1,019,367.
So, in less than 1.5 months the chairman bought in the open market more than 3 times what he previously owned directly.
This ain't a token purchase and he is not doing it to prop up the price. IMO, he's doing it to make a profit.
The dividend stinks and will continue to stink until the buildout is finished, so it must be appreciation he is after.
Is this a prelude to Grupo taking out the non-grupo shareholders at a small premium or is it just he knows the price is too low compared to future prospects???? Don't know the answer, but am glad to see the chairman speaking so loudly with his own cash that he thinks the price is too low.