Golf Course PPA

If you’re a syndicator or real estate investor wondering how to stand out in a tough market, this is definitely required listening.

Chapters

[00:00] Introduction — Mike previews the golf course deal and why he’s never been more excited about a client project

[00:47] Setting the stage — Kevin and Mike describe how the initial call came in before the offer was submitted

[01:25] The client — Josh, a syndicator at Accountable Equity who builds high-end resort destinations

[02:24] The key lesson — Why calling your CPA before you make an offer is worth millions

[03:11] The golf courses — Two high-end courses being purchased together

[05:26] IRC 1060 and the PPA opportunity — How Mike realized this was a purchase price allocation deal, not just a cost seg

[07:50] What’s really under the grass — Drainage systems, bunker retaining infrastructure, composite greens sub-bases

[10:00] The numbers — Why the allocation exceeded the 30% investors were originally expecting

[11:30] Negotiating with the seller — The seller’s tax director, the recapture question, and why it worked

[13:00] Investor classes — Designing different return structures for different investor needs

[16:30] The hotel and marina — Josh’s resort plan and the financing challenge

[17:30] IRC 721 contribution — How the hotel and marina owners joined the deal tax-free

[19:00] Career highlight — Mike calls this a top-five moment in his twenty-six-year career

[19:57] Wrap-up and CTA for syndicators

In the latest episode of the Hidden Money Podcast, Mike and Kevin walk through one of the most creatively structured deals of Mike’s twenty-six-year tax career: a golf course acquisition where purchase price allocation under IRC 1060 produced extraordinary depreciation for investors, multiple investor classes were structured to accommodate different investor needs, and a neighboring hotel and marina were contributed into the deal tax-free under IRC 721.

If you’re a syndicator or real estate investor wondering how to stand out in a tough market, this is definitely required listening.

Chapters

[00:00] Introduction — Mike previews the golf course deal and why he’s never been more excited about a client project

[00:47] Setting the stage — Kevin and Mike describe how the initial call came in before the offer was submitted

[01:25] The client — Josh, a syndicator at Accountable Equity who builds high-end resort destinations

[02:24] The key lesson — Why calling your CPA before you make an offer is worth millions

[03:11] The golf courses — Two high-end courses being purchased together

[05:26] IRC 1060 and the PPA opportunity — How Mike realized this was a purchase price allocation deal, not just a cost seg

[07:50] What’s really under the grass — Drainage systems, bunker retaining infrastructure, composite greens sub-bases

[10:00] The numbers — Why the allocation exceeded the 30% investors were originally expecting

[11:30] Negotiating with the seller — The seller’s tax director, the recapture question, and why it worked

[13:00] Investor classes — Designing different return structures for different investor needs

[16:30] The hotel and marina — Josh’s resort plan and the financing challenge

[17:30] IRC 721 contribution — How the hotel and marina owners joined the deal tax-free

[19:00] Career highlight — Mike calls this a top-five moment in his twenty-six-year career

[19:57] Wrap-up and CTA for syndicators