Wednesday, April 27, 2011
While it's no secret that there are many people in this country or around the world who share any given name, this fact is magnified by the existence of social networking sites like Facebook and LinkedIn and search engines like Google. For example there are hundreds of people that share my name on Facebook alone, and a Google search of even the most unusual name typically retrieves numerous hits. Which makes it surprising that in last night's dream about an imaginary baseball player who had been traded to the New York Yankees in a 16 player deal, I came up with an ordinary enough name that registered zero hits on Google. Except, there's this one now.
Tuesday, April 12, 2011
After twenty some odd trips to New York City, I finally made it during the spring time. Most of our trips have been in the winter, and it turns out that these visits have given us a skewed view of the city, and I'm not talking about the weather. Rather, seeing the crowds in Manhattan, especially Times Square, I was overwhelmed by the wall to wall people this week that isn't there in the winter. Two things appeared particularly noteworthy about the crowds. First of all there were large numbers of school groups, presumably visiting New York for a spring vacation field trip. Secondly, hordes of European tourists, likely taking advantage of the weak dollar. I'm guessing every other guest in my hotel was from Europe.
Also interesting is the weather. It was in the 50s and cloudy on Friday, Saturday, Sunday and today (Tuesday). It was 80 degrees and sunny yesterday afternoon, though it was still cloudy and cool at 11 am. That would never happen in California. I guess yesterday they had what is referred to as a warm front, a term unheard of back home.
Also got to see the Spiderman musical, now in its fifth month of previews, and ready to officially open in about two months. No cast or crew were injured during my performance of the show.
Finally, made my first official visit to the Bronx. We did get lost in the Bronx late at night 7 years ago after inadvertently exiting from the freeway (can you say Bonfire of the Vanities?) and almost crossing a bridge to who knows where, but this was the first visit, on purpose and on the ground. Yankee Stadium was a tremendous disappointment, as the new stadium is sterile and nothing is visible from the outside. But Fordham Road was tremendous with the wide boulevard, vibrant shops, and Carribean residents.
- Partnership liquidating distributions are almost never made in accordance with capital accounts as directed by the 704(b) safe harbor, except where for fractions rules partnerships. With today's complicated profit and loss allocations, errors are commonly made, and liquidations in accordance with capital would deviate from the economic deal. The fix is made, rather, in future year allocations.
- Deficit restoration obligations are uncommon, too, due to the potential economic liability
- The Sec. 1223 rule bifurcating the holding period of a partnership interest for each capital contribution can be remedied to the extent a current year contribution is offset by a current year distribution
- Direct ownership of a US corporation owning real estate is acceptable with foreign investors whose primary concern is not having to file personally with the IRS. FIRPTA exception for liquidation of USRPHC which has liquidated all its properties avoids the double tax. However, more sophisticated investors will use a tax haven foreign corporation/US subsidiary structure to also avoid the estate tax.