2 Real Estate Accounting Potpourri Presented by: Jason Thompson Kimberly Brown and Stephanie Onzay
3 Tax Consequences of Debt Discharge & Foreclosure Rules
4 Outline Tax consequences of forgiven debt if: Insolvent or bankrupt Solvent and not bankrupt Tax consequences of foreclosure if recourse/non-recourse debt and: Insolvent and bankrupt Solvent and not bankrupt
5 General Rules & Exceptions General Rule When a lender discharges all or part of a borrower s debt, the discharged amount must be included in the borrower s gross income for federal income tax purposes (IRC Sec. 61(a)(12)) Income from discharged debt is COD or cancellation of indebtedness income Exceptions IRC Sec. 108(a)(1) Gross income does not include any amount which (but for this code subsection) would be includible in gross income by reason of the discharge (in whole or in part) of indebtedness of the taxpayer if (A) title 11 bankruptcy case, (B) taxpayer is insolvent (at partner level if partnership, at S-Corp level if S-Co.), (C) qualified farm indebtedness, (D) in the case of a taxpayer other than a C Corporation, qualified real property business indebtedness, or (E) qualified principal residence indebtedness which is discharged before January 1, 2013
6 Price to Pay!! IRC 108(b) Price to pay for excluded debt if insolvent Certain tax attributes of the borrower (such as NOLs and capital loss and tax credit carryovers) may have to be reduced as the price to be paid for taking advantage of the bankruptcy and insolvency exceptions
7 Exceptions for Solvent Taxpayers A Taxpayer who is not insolvent or bankrupt can elect to exclude income from the discharge of qualified real property business debt (IRC Sec. 108(a)(1)(D)) C Corps cannot make the election Qualified Real Property Business Debt Debt that was incurred or assumed before 1/1/93, in connection with real property used in a trade or business, and that is secured by such real property, or On or after 1/1/93 and is debt incurred or assumed to acquire, construct, reconstruct, or substantially improve real property used in a trade or business. Election must be made on Form 982 in the taxpayer s timely-filed return for the tax year in which the discharge occurs Excluded income cannot exceed the lesser of: The excess of the outstanding debt principal (immediately before discharge) over the FMV of the real property securing the debt or The aggregate adjusted bases of all depreciable real property held by the taxpayer determined as of the first day of the tax year following the discharge
8 Debt Forgiveness Example KSJ Partnership purchased an apartment at the peak of the local real estate market KSJ paid $250,000 for the property and financed 100% of the purchase price Property s value dropped to $200,000 In 2010, KSJ found a buyer to pay $200,000 and then renegotiated the principal balance with the bank from $250,000 to $200,000 KSJ sold the property and paid off the $200,000 renegotiated mortgage and walked away with no out-ofpocket loss. The partnership was liquidated before the end of the year.
9 Debt Forgiveness Example Cont. Tax consequences of renegotiated debt Original bal. $250,000 Renegotiated bal. $200,000 COD Income $50,000 * KSJ partners can exclude their share of the COD income if they are insolvent or bankrupt but the attribute reduction rules will apply *If they are solvent and not bankrupt they may be able to make the election to exclude the income under the qualified real property business debt rules if applicable. Otherwise they have taxable gross income from the forgiven debt.
10 Tax Consequences of Foreclosure Step 1: Is debt non-recourse or recourse? Is the taxpayer solvent or insolvent? Remember if partnership determined at the partner level, if S-Co. determined at the S-Co. level Non-Recourse Debt: Foreclosure of non-recourse debt creates deemed sale of asset with sale price equal to debt Since the sales price equals the full amount of the non-recourse debt, there is no debt discharge income resulting from a foreclosure or deed in lieu of transaction involving only non-recourse debt Not favorable for bankrupt or insolvent taxpayers who can exclude COD income from taxable gross income but cannot exclude a potential taxable gain on the deemed sale back to the bank
11 Example Foreclosure - Non-Recourse K&S JV purchased 160 acre land parcel on 7/1/06 for $320,000. Kimberly & Stephanie paid $32,000 down, with the balance due under a non-recourse contract for deed with the seller. Annual payments of $10,000 or principal plus interest are due each July 1. K&S made payments on 7/1/07 & 7/1/08. Due to lower local real estate prices in July 2009, they determined it was not beneficial to continue making payments because the land s value had decreased to $200,000 per an appraisal and the debt was $268,000. K&S negotiated to surrender the land back to the seller in full satisfaction of the debt. This transaction occurred on 12/1/09.
12 Example Foreclosure Non-Recourse Cont. Tax consequences: Sales Price = Debt $268,000 Adjusted basis $320, Gain/Loss ($52,000) NOTE: No debt discharge income because the debt was all non-recourse and the sales price equals the debt
13 Foreclosure with Recourse Debt Can result in COD income Transfer of property back to the lender is a deemed sale with proceeds equal to the lesser of the FMV at the time of foreclosure or the amount of secured debt If the debt exceeds the FMV, the difference is treated as debt discharge income to the extent it is forgiven (Reg & Rev. Rul )
14 Foreclosure with Recourse Debt Cont. The foreclosure sale transaction and the debt discharge transaction are treated as unrelated events for tax purposes FMV is a critical factor in the tax treatment of a foreclosure transaction. It is helpful for the borrower and the lender to fix the value of the foreclosed property so the gain or loss on the deemed sale and debt discharge income can be determined without controversy.
15 Recourse Foreclosure Example K&S JV bought a commercial building on 1/1/06 for $500,000, with $50,000 allocated to the land and $450,000 to the building. K&S JV financed the purchase with a $450,000 recourse loan from the bank and a $50,000 cash down payment. Each year $5,000 of principal is due. From , K&S paid $5,000 of principal each year. During the first half of 2009, it paid $2,500 of principal then ceased making payments because of financial difficulties. At 12/31/2009, the outstanding debt was $432,500 and K&S s adjusted basis in the building and land after depreciation was $405,250 K&S transferred the property s deed to the bank in lieu of foreclosure on 12/31/2009. The bank then discharged the partnership from any further liability on the loan. The FMV of the property on 12/31/2009 was $425,000.
16 Recourse Foreclosure Example Cont. Step 1 Calculated gain/loss on transfer to bank: Recourse Non-Recourse FMV $425,000 $432,500 AB ($405,250) ($405,250) Gain $19,750 $27,250
17 Recourse Foreclosure Example Cont. Step 2: Calculate COD Income solvent: Debt bal. $432,500 FMV $425,000 COD Income $ 7,500 NOTE: For solvent taxpayer, COD income cannot be excluded unless it is qualified farm debt or qualified real property business debt. If taxpayer is insolvent, COD income is excluded and the attribute reduction rules apply.
18 IRC 108(i) Election IRC 108(i) provides that a taxpayer can elect to defer the inclusion of certain COD incurred in connection with a reacquisition of an applicable debt instrument during the period 1/1/2009 through 12/31/2010 The election allows the taxpayer to defer the recognition of income ratably over five years beginning in 2014.
19 GAAP for Troubled Debt Restructurings, Modifications and Extinguishments
20 Financial Statement Impact What is the impact on the P&L? What does this mean for the impairment analysis on the related assets? Required disclosures
21 Financial Statement Impact Cont.
22 Troubled Debt Restructuring Relevant guidance: ASC What constitutes a TDR? A creditor grants, for economic or legal reasons, a concession that would otherwise not be considered because of the debtor s financial difficulties. The creditor agrees to this to protect as much of its investment as possible. Requires judgment
23 Troubled Debt Restructuring Cont. Underlying principle: substance of the transaction May be a TDR for the debtor but not for the creditor Groups of liabilities may be negotiated but the TDR evaluation is at the individual liability level
24 Troubled Debt Restructuring Cont. Types of TDRs Transfer receivables, real estate or other assets to creditor to fully settle payable Assets transferred at fair value and gain recorded Modification of terms Prospective accounting, no gain unless future cash flows, including interest, are expected to be less than existing carrying value
25 Troubled Debt Restructuring Cont. Other considerations Contingent payments Variable interest rates Legal fees and other direct costs Equity interest
26 Troubled Debt Restructuring Cont. Disclosure requirements Changes in the terms of the debt Any gain from the restructuring of payables Net gain or loss from the transfer of assets to satisfy all or a portion of the obligation
27 Debt Modifications Is it a modification or extinguishment? The 10% rule applies Treatment of loan fees and other costs Modifications to lines of credit and revolving debt
28 Debt Classification & Disclosure Covenant violations Subjective acceleration clause Remote or likely? Callable debt Refinance short term to long term Impact of these items on going concern
29 Other Areas of Interest Impairment analysis Fair value analysis Moss Adams has valuation experts to assist where needed.
30 Energy Credits & Incentives and Repair & Maintenance Expenditures
31 Variety of Energy Incentives Available Federal Tax Incentives State Tax Incentives Non-tax Economic Incentives Grants Others Loan Guarantees Utility Rebates
32 Federal Energy Incentives Production Tax Credit (IRC 45) Credit against tax liability based on energy produced over a period of years (wind, geotherm, solar) Manufacturer Credits (IRC 45L & 45M) Expires 2009/2010 Manufacture of efficient homes & appliances Credit on a per unit basis for exceeding efficiency threshold Energy Tax Credit (IRC 48) 1 st Year credit against tax (geotherm, solar, fuel cell) US Treasury Cash Grant Cash grant provided within 60 days of submitted application Large scale alternative energy projects Accelerated Depreciation Deductions 5 year recovery for specified Energy property IRC 179D (Energy Efficient Buildings) Expires 2013 Nonbusiness Energy Property Credits (IRC 25C) 30% credit expires 2010 Insulation, windows, doors, skylights, roofs, geothermal, A/C
33 Key Points Taking advantage of energy incentives requires planning In service dates Start of construction dates Design / equipment standards met The incentives are just incentives The available energy efficiency incentives do not necessarily pay for the incremental design / equipment costs incurred Resource Database of State Incentives for Renewables & Efficiency (
34 Repairs and Maintenance - Summary of Regulations Repairs does not increase value does not prolong life Example: Incidental repairs Repair to keep property in ordinary efficient operating condition Capital Expenditures 1.263(a)-1 increase value increase economic life adapt property to a new or different use Example: New building Permanent improvement Betterment Restoration Replacing exhausted/deteriorated property The question you must ask yourself is what constitutes an increase in value or life? It s all a matter of the facts and circumstances. There is no bright lines test.
35 Repairs and Maintenance Summary Very facts and circumstances driven Similar work scopes may have two different answers, depending on underlying facts Tier 1 issue with the IRS Rev. Proc added repair and maintenance expenditures to the list of valid automatic accounting method change Consultation is key
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