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Valuing Like Kind Exchanges: Is It Too Good to Be True?
How would you as a lessor like to increase your after tax income by millions of dollars? How would you as lessor like to increase spreads by 30 basis points? Would you like to do this without having to cut costs or take the risk of creating a new product, entering a new market and hiring lots of staff? The answer to these questions of course is “yes,” and it sounds too good to be true as the way to get there is to use a gift from the IRS ' implement a Like Kind Exchange (“LKE”) program in your leasing business.
The focus of this article is on how to value an LKE program.
The Like Kind Exchange tax benefit derived from section 1031 in the IRS Code has been used in real estate transactions for years and more recently in large ticket tax lease transactions like commercial aircraft. Increasingly, it is being used by equipment lessors that have portfolios of assets under tax leases. The benefits of an LKE program have traditionally been in cases where the leased assets were assets that retained strong residual values like aircraft, rail equipment, trucks, trailers, autos, construction equipment, and lift trucks. Now with Bonus Modified Accelerated Cost Recovery Systems (“MACRS”), LKE programs even show benefits for PC and copier leases as those leases are showing tax gains on termination, especially early terminations. The challenges in implementing an LKE program in a medium to small ticket leasing business are complexity, volume and the cost/benefit, but those challenges can be overcome through the use of experienced LKE software and service providers. They advise on the tax rules, set up the systems to comply with the tax rules and handle the volume. Often their costs are low enough to create high value.
Yachts, Jets, Horses & Hooch: Specialized Commercial Leasing Models
Defining commercial real estate asset class is essentially a property explaining how it identifies — not necessarily what its original intention was or what others think it ought to be. This article discusses, from a general issue-spot and contextual analysis perspective, how lawyers ought to think about specialized leasing formats and the regulatory backdrops that may inform what the documentation needs to contain for compliance purposes.
Hyperlinked Documents: The Latest e-Discovery Challenge
As courts and discovery experts debate whether hyperlinked content should be treated the same as traditional attachments, legal practitioners are grappling with the technical and legal complexities of collecting, analyzing and reviewing these documents in real-world cases.
Identifying Your Practice's Differentiator
How to Convey Your Merits In a Way That Earns Trust, Clients and Distinctions Just as no two individuals have the exact same face, no two lawyers practice in their respective fields or serve clients in the exact same way. Think of this as a "Unique Value Proposition." Internal consideration about what you uniquely bring to your clients, colleagues, firm and industry can provide untold benefits for your law practice.
Risks and Ad Fraud Protection In Digital Advertising
The ever-evolving digital marketing landscape, coupled with the industry-wide adoption of programmatic advertising, poses a significant threat to the effectiveness and integrity of digital advertising campaigns. This article explores various risks to digital advertising from pixel stuffing and ad stacking to domain spoofing and bots. It will also explore what should be done to ensure ad fraud protection and improve effectiveness.
Turning Business Development Plans Into Reality
This article offers practical insights and best practices to navigate the path from roadmap to rainmaking, ensuring your business development efforts are not just sporadic bursts of activity, but an integrated part of your daily success.