Case 3


Partnership Deficit Capital Account Solution

A partnership had restructured the debt on its property, giving all of the economics to the lender, in exchange for being allowed to stay in the partnership so as to avoid recognizing the gain from foreclosure.

The time had come, however, when the lender was thinking of selling the property, and they were going to realize a $17mm gain, and a tax bill of taxes resulting of about $5mm.

With a portfolio of net lease property from Net Lease Capital, the partnership was able to defer the tax for an end cost of about $1.5 million.  The partnership would then liquidate the partners by distributing out the property to them, a non-taxable event, allowing the partners to trap their gain in the distributed property, in which they would have a tax basis of $0. The partnership gets a basis step in the remaining partnership property, reducing its gain when they ultimately sell it.

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