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Tax Reform and Organizational Forms for Holding Investment Real Estate: Corporation vs. Partnership

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  • George H. Lentz
  • Jeffrey D. Fisher

Abstract

Following the ERTA of 1981, partnership ownership of real estate dominated corporate ownership. This study concludes that the Tax Reform Act of 1986 provides incentive for holding real estate investments that produce sizable tax losses and/or that are eligible for large tax credits in corporate rather than partnership form. Perpetuity cash flow models are employed initially to identify key tax and cash flow variables favorable to each organizational form. The perpetuity assumption is then relaxed to consider a more representative real estate investment. A sensitivity analysis examines the extent to which the base case results are dependent on the assumed values of selected model parameters.

Suggested Citation

  • George H. Lentz & Jeffrey D. Fisher, 1989. "Tax Reform and Organizational Forms for Holding Investment Real Estate: Corporation vs. Partnership," Real Estate Economics, American Real Estate and Urban Economics Association, vol. 17(3), pages 314-337, September.
    • Handle: RePEc:bla:reesec:v:17:y:1989:i:3:p:314-337
    DOI: 10.1111/1540-6229.00494
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    References listed on IDEAS

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    5. E. Philip Jones & Robert A. Taggart, Jr., 1984. "Taxes and Ownership Structure: Corporations, Partnerships and Royalty Trusts," NBER Working Papers 1441, National Bureau of Economic Research, Inc.
    6. James R. Follain & Patric H. Hendershott & David C. Ling, 1987. "Understanding the Real Estate Provisions of Tax Reform: Motivation and Impact," NBER Working Papers 2289, National Bureau of Economic Research, Inc.
    7. Fama, Eugene F & Jensen, Michael C, 1983. "Separation of Ownership and Control," Journal of Law and Economics, University of Chicago Press, vol. 26(2), pages 301-325, June.
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    2. Marion Steele, 1993. "Conversions, Condominiums and Capital Gains: The Transformation of the Ontario Rental Housing Market," Urban Studies, Urban Studies Journal Limited, vol. 30(1), pages 103-126, February.

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