Real Estate

Our clients use leasing as a common financing tool in the purchase of large- and medium-scale real estate investments.  Single tenant buildings, corporate headquarters, manufacturing plants, industrial warehouses, and large retail structures have all benefitted from upfront capital provided by lessors with tax capacity.

ABC allows for structures with multiple asset classes: building, site improvements, personal property, and land.  Transactions are subject to different IRS safe harbor rules, including a more generous uneven rent test and a longer allowable rent holiday.  Like equipment leases, real estate leases are optimized using 467 rental structures, and these leases are often financed by non-recourse leverage.  However, they have more flexibility than traditional leases in the amount of debt and timing of debt repayment, since they are not required to adhere to the same pre-tax IRS tests.