Team 4 Wulfert Point and the Sanctuary Golf Club: (the Organization Chart structured to be utilized in structuring the lease/purchase of the property giving consideration to a syndication to raise capital for the development of the property is provided below.)
The original purchase of the Wulfert Point property for $20,000,000 involved the acquisition of an old key lime planation in a protected area or nature preserve on Sanibel Island, Florida. In order to secure approval for development density was dramatically reduced and hundreds of acres were donated to the Federal Wildlife Association and additional acreage set aside for an eagle preserve. Your “team” of four individuals is developing Wulfert Point.
- One eighteen hole golf courses with club house and golf practice facilities
- 5 Hospitality Suites in the Club House and Condos (108)
- Swimming pool
- 14 villas
- 106 single family lots
- 13 Duplex lots
- Tennis center, Fitness center and Spa
- Club House dining facilities.
- Construction of a sewage treatment facility
- Commitment for affordable housing
- Infrastructure including roads, power, water and sewer.
Address the following:
- Address the tax elements of the ownership and operation of the “Hospitality Suites” utilized for overnight accommodations as a separate entity discussing the various forms of depreciation (1231 property – equipment, furniture, fixtures and buildings), allocations between land and buildings, operating expenses and capital expenditures. Cite relevant tax code sections.
- Address the tax elements of selling condominiums, real estate lots as a separate development entity, discussing the allocations between land and buildings, operating and selling expenses and capital expenditures and taxes ( capital gain or ordinary income and why) on sales of condo units. Consider sales office and model apartments. Cite relevant tax code sections when necessary.
Consider whether any of the above may be considered “Dealer Property” and recommend an accounting method and accounting period if applicable to the various aspects of the venture. Please discuss the distinction between operating expenses, startup expenses and syndication expenses and what needs to be expensed and capitalized with respect to each of the seven organizational structures and operations above. Also consider whether shorter recovery periods may apply to various components of the development.
thought about killing French citizens in order to remain in power, for instance, in 1795, he did not hesitate to down the Parisian mob with cannons. Even though he spread conflict, Napoleon’s wars spread new ideas and institutions throughout Europe, reforming European tradition and spreading democratic and liberal ideas throughout, directly influencing the development of Europe which can still be seen in current day. He looked beyond partition and ideological attributes and recognized exceptional skills and talents that could support his vision of France. As Napoleon once said, “I care only for people who are useful to me, and only so long as they are useful.” These words portray his selfishness and control, but he remained a shining knight in armor to the people of Paris. What is a Tyrant? A Tyrant is someone who is a cruel and oppressive ruler, ruling with absolute power. What is a Hero? A hero is someone who is idealized for courage, outstanding achievements, or noble qualities. As a hero to the people of France and a tyrant to absolutist monarchists and neighboring countries, Napoleon rightly fits into both categories of the spectrum, as he honoured some principles of the Revolution and betrayed others, gave the people of France some freedom, but ruled with an iron fist. As a hero, Napoleon created the Napoleonic code and rebuilt France. As a tyrant, Napoleon abolished women’s rights and ruled as an absolutist dictator. As both, he became one of the most influential figures in European history, living on as a Heroic Tyrant.>GET ANSWER