Analysis of capital gains or ordinary income characterization hinging on possible treatment of taxpayer as a ‘dealer’ in parking licenses where transfers occur in bulk to separate taxpaying entity after which subsequent transactions might occur at the retail level.  Analysis of step transaction doctrine, related-party sales rules and attribution of activities under relevant case law.

Discussion, advice and documentation relating to distribution of units in development where initial investors had designated individual units for distribution at completion of construction but were prevented from fully binding transfer by restrictions of plan documents.  Analysis of RPTT mere change of form of ownership rules applied to bespoke situation and best approach to documenting ultimate transfer of title.

Numerous situations of in-kind distribution of promoter units and multi-promoter structures, application of mere change of form to varying factual situations as well as assumption of mortgage and mortgage recording tax in similar situations.  Review of ACRIS documentation to conform with NYC and NY State RPTT rules and regulations.