Selling L/O or CFD

I have a house taken sub2.

I have been talking to several people about my plans to sell on a Land contract. Their experience seems to indicated that L/O is the way to go.

I see a lesser down/ payment with the L/O and the renter mentality.

I see a Bigger Down, and a Buyer for my house not a tenant.

Their point is that in Michigan it is nearly impossible to get rid of a no paying Mortgage Contract holder and much easier to get rid of a tenant.

However I again see that a buyer is more likely to want to pay for a house they can get a Mortgage interest deduction than the rent.

As an exit strategy what is better for Michigan in your opinion?

What am I missing in this argument?

Not in Michigan, so take it for what it’s worth.

Are you SURE that you’ll get a bigger down with a CFD as opposed to a lease option? Or is that just your opinion.

What are the laws in MI for CFD’s and leases? Will you be required to foreclose on a CFD where a simple eviction will work on a lease?

A tenant in a lease option, if structured correctly, has the buyer mind frame just as much as a CFD buyer.

CAN they actually get a mortgage interest deduction on their taxes? Have you talked this through with a CPA?

Something that’s not in your post. What is the tax consequences of a CFD or a L/O? With a CFD, the taxman will consider that a sale “in full” whether or not you actually collected the full sales price upfront. In short, you buy for $75K and sell on CFD for $100K, $10K down, $1K/month. The IRS will view you as making $25K in profit that year, not $10K plus the $100-200/month cashflow. Plus that profit is taxed as ordinary income, complete with self-employment tax and all. Can you foot the bill?

By contrast, in most cases, a L/O is considered a rental and has all of the tax breaks associated with rentals. Plus, if you wait to sell for at least 12 months, any income that you receive will be taxed at the capital gains rate, currently at 15%.

Raj

Hard to find a CPA that agrees with another CPA or even knows what Sub2 is. They don’t understand it. but a couple that I have talked to in trying to interview have said that you only pay when you complete. One said that they (the IRS) would treat the down and final as taxable at the completion of the sale and the monthly pac as taxable in the year it was received. Ie the interest on on a L/C would be treated as income but the rest would be capital gains.

I had another tell me that it did not matter if it was L/O or a land contract. It is the intent to sell that makes it a dealer tax status. So the tax would be the same.

Problem is most that I have talked to so far do not have any REI clients besides rental people and the like. So a consistent answer has not been given to me. I don’t want to pay a lot of tax but I also don’t want to have to make up back payments/ penalties if I get it filed wrong. CPA’s don’t cover those if they make a mistake, you do, as it is your tax burden.

Also if I have to pay the taxes up front, it would be impossible for me to cover the seller’s mortgage with a 3 month escrow. At the 40-50% tax rate up front I would have to come out of pocket to pay the taxes. The down would not be enough to cover that.

I f I sell on a L/O I have a problem with the Rental rates. Right now 100k houses sell for 100k, but they rent for $500-600 per month. Rent rates have not kept up with appreciation on the house price. It would be a hell of an option extra to pay per month and I think that I might lose out.

Can you evict someone who is paying rent, but decides to forego the option payment and quits the sale? No as I understand it you can’t. At least if you separate the Lease and the option in two separate contracts which is something that a lot of gurus tell you to do. I got this from a lawyer. He said you can only deal with each contract as is basis. if you link the conditions of one to the other it then becomes a L/C again anyways.

It becomes a very confusing issue the more I talk to experts.

I am looking for a source or reference or book that I can study that covers this issue and then maybe pass on to the CPA if I find one that like. So far they don’t seem familiar and they contradict each other on opinion. All of the REI people out there and none are CPA’s? Surely one has written a Beginners guide?

Framer 35,

Lease options can be tricky. You had better make sure you have a good tenant or else the “equitable interest” argument will jump up and bite you on the bottom. You’ll have to foreclose, rather than evict.

You are much better off doing a wrap, or better yet, placing the property in a land trust, then triple net leasing it. Simple eviction, much higer rents, plus asset protection.

Da Wiz

Framer,

I’m with you on seller financing and plan to do it in Michigan as well. I know a HIGHLY successful REI that uses this strategy (not in MI). He says that if you demand a large enough downpayment then your risk is pretty minimal.

It’s typical to make them keep your financing for at least 1 year (for tax reasons) and they have a balloon payment due before the end of year 3. That’s when they have to refinance and that will unlock your equity.

Michigan does have some owner friendly foreclosure laws. Just make sure your downpayment is large enough to cover that risk.

As to a L/C - CFD being taxed as a sale or tax as a loan, you’ll have to go with your gut on what you think is right (or look it up yourself). By law, if you have not owned the property for at least 12 months, then a CFD is not viewed as a installment sale, but rather a sale in full. Personally, I’d find another investor or two and get some recommendations on CPA’s

I guess I’m a little confused on your L/O problem about paying an option and rent and eviction. When you lease option something, the tenant pays an option fee upfront. Then they lease the property for whatever time frame that you lay out. In your option contract, you should have something to the effect that if the lease is broken/violated/eviction/etc, then the option contract shall be voided. Again, simple answer to have your attorney review for the best for your plan.

And for the Doc’s post, a properly structured lease and option agreement does NOT give any equitable interest in the property. The option fee is paid to the optioner/seller for the OPTION to purchase the property. Having an option gives you no interest in the property other than the ability to buy it for a set price and terms. And you can offer a triple net lease whether or not it’s in land trust.

Raj

Your tenant is not legally entitled to the tax or interest writeoffs unless it’s in a trust. In addition, more and more jurisdictions are saying that lease options are “disguised sales”, whether or not there is one or more than one doc.

At least that’s the case in Arizona.

Da Wiz

Doc,

As you well know, states vary greatly on their RE laws and even on their enforcement of those laws.

Yes, many times a deal labeled as a lease/option has been decided by the courts to be a disguised sale. However, my point was that those were not properly executed leases with options to purchase. And simply separating the agreements is not what I meant.

Some things that have the potential to make a L/O a “disguised sale:”
An ongoing monthly option payment in addition to a lease payment.

Referring to the option fee in any of the paperwork as a “down payment.” An option fee is NOT a down payment. It is the fee that is given for the option contract.

Setting up an amortization schedule for the lease/option.

Giving a term longer than 3 years on a lease and option.

Making the tenant responsible for ALL the repair costs.

Giving a set monthly rent credit that goes toward the principle or the downpayment.

Raj

Gary

The problem with your triple net lease, which you used to call a NARS trust right? Is that I have the deed, in my LLC’s name. You are putting the seller’s name as a 10% interest on the trust. Also again, and I reiterate, I have now three different Lawyers from the state of Michigan, tell me that in Michigan, it is not a very good Idea to use a trust to convey real estate except for in estate planning. And as I am going to buy it I can not just have the beneficial interest transfered to me. Rather I can but that opens me up to more problems that just getting the deed.

I know, find a different lawyer, but until I do, I would be prudent to follow their advice for now. Unless you would like to defend me free of charge or hire the right Lawyer for me.

But I agree with you about the L/O and the equitable interest. Contract law in Michigan tends to make the L/O become a L/C. It is a dance it looks like. Either they are a tenant with an option and therefore you are a land lord with all duties to repair and maintain, or they are buying the house on contract for the deed. And then if I do a L/C I have to be careful of the Dealer issue. At the very least there are some guidelines for that with the IRS. That being you can give the buyer the right to maintain, and improve but with permission. This tends to make it show that you have not completed the sale in spirit as well money exchange.

In Michigan, I am seeing that the foreclosure laws are saying 3 month on a L/C versus 6 months for a wrap around mortgage. The difference being that the buyer is not getting the deed and it is a purchase performance agreement that says the deed will be given if the buyer holds up his end of the agreement, but this is not a certainty on his part so the foreclosure laws are better for this.

Roger that is some good advice about the lease options. I am still looking into it.

As far as talking to other Investors about a CPA. I am trying to find a local one one with out having to drive 2 hrs. Bad enough some of my deals are going to be that far away, this first one is. Most of the investors that I am encountering are not from my area. These are the ones that I am finding from my ads. They see my ad and then call me to say hello and see if I am a threat to their way of doing things, or if they can pawn off a bad deal onto me.

Still looking for the CPA. Right now they seem to be very busy and don’t have time.

Hi framer,

If the deed is in your name, that’s easy. You’ve already acquired the property, a valuable asset, now you must manage it.

You place the property into a land trust, name your trustee, and find a tenant who agrees to live in the property, make the payments and be responsible for maintenance and repairs under a triple net lease. If he will do that, you will GIVE him IMMEDIATE home ownership benefits by assigning him a 50% beneficiary int. in the trust, in exchange for a HIGHER RENT. (Retain 50% for yourself). For tax purposes, the IRS considers him an owner of the property and he is entitled to writeoff the mortgage interest and property taxes. To top it off, you agree to share future appreciation 50/50.

You’ll have a positive cash flow, your tenant sends the rent direct to your payment processing company who pays the mortgage and you just receive a check every month. If your tenant defaults, it’s always a simple eviction.

You’re in a great situation with strong asset protection in the trust, and look what you have done for your tenant:

Your Tenant/Resident Beneficiary is effectively buying a house on a seller-carry…100% percent of it.
He gets 100% of the property;
100% of the income tax write-off;
100% of the use, occupancy and possession;
100% of any water and/or mineral rights that go with the property;
100% of the right to refinance in his own name at the termination of the agreement;
100% of all the asset protection the trust provides;
100% of his down payment made by someone else;
100% of his credit qualifying done by someone else;
100% of the right to ALL the benefits of Fee Simple Real Estate ownership without credit or bank qualifying or the standard up-front cash.

The only thing he is not getting is whatever equity the non-residents (YOU)have at inception and possibly some percentage 50% of the future appreciation potential…which appreciation may never happen…in which event he’s even gotten 100% of the non-appreciation and made a great deal for himself.

As you can see, I combine my land trust “subject to” with a triple net lease and an equity share. Never look at an “Equity Share” scenario as only owning part of something: the resident owns it all, he just agrees that in exchange for his good fortune in being able to acquire a home with all of his shortcomings, he’ll happily share some of the future appreciation with his Benefactor (YOU)…but only if there is ever to be any.

You feel like Santa Claus and make a nice return on your investment with virtually no risk.

Da Wiz

Framer,

Can you point me to this 3 month for L/C law in Michigan? That’d seriously make my day.

Thanks!

Here it is straight off of the Michigan statute site.

REVISED JUDICATURE ACT OF 1961 (EXCERPT)
Act 236 of 1961

600.3115 Foreclosure proceeding; sale, time.
Sec. 3115.

Whenever a complaint is filed for the foreclosure or satisfaction of any mortgage on real estate or land contract, the court has power to order a sale of the premises which are the subject of the mortgage on real estate or land contract, or of that part of the premises which is sufficient to discharge the amount due on the mortgage on real estate or land contract plus costs. But the circuit judge shall not order that the lands subject to the mortgage be sold within 6 months after the filing of the complaint for foreclosure of the mortgage or that the lands which are the subject of the land contract be sold within 3 months after the filing of the complaint for foreclosure of the land contract.

History: 1961, Act 236, Eff. Jan. 1, 1963

That’s great. Thanks!

Gary

Your Tenant/Resident Beneficiary is effectively buying a house on a seller-carry…100% percent of it.
He gets 100% of the property;

Meaning what? That he gets to live there and use it as he sees fit barring any major changes to the structure? He can do that anyways. What about taking an equity loan out? I don’t want him to do that, especially if he defaults, then I have another lien against the property. How would I be able to resell it if he put a 125% LTV second mortgage on it?

100% of the income tax write-off;

Did you mean the Interest paid Tax deduction? He gets that already with the IRS on a Land Contract.

100% of the use, occupancy and possession;

Personally i do not want my buyer having total rights to demolish and rebuild the house as he deems fit until he has refinanced [/b]

100% of any water and/or mineral rights that go with the property;

It’s a small lot, in a village with municipal services.

100% of the right to refinance in his own name at the termination of the agreement;

The Land Contract already does this. And actually he could do this early, I would just try to write into the agreement so that he has to be there for a year at least. For dealer taxation issues I believe.

100% of all the asset protection the trust provides;
100% of his down payment made by someone else;

Who is this? His Uncle? I am not going to pay his down payment, I want his down payment.

100% of his credit qualifying done by someone else;

This is where a mortgage broker and a LSC will come in handy anyways.

100% of the right to ALL the benefits of Fee Simple Real Estate ownership without credit or bank qualifying or the standard up-front cash.

If they are leasing it they are not owners, I can not evict them if they have Fee Simple ownership. Definition “fee simple estate
An unconditional, unlimited estate of inheritance that represents the greatest estate and most extensive interest in land that can be enjoyed. It is of perpetual duration.”

If there is no upfront cash, how do I get money from a down? This would hurt me I think.

But placing the property into a trust after I have taken possession of it is a good idea I think. Just for my asset protection. But I don’t need a fancy and complicated NARS, PAC or Triple Net Lease type trust. My LLC owns it, so I should be able to create a trust for it after taking title with My LLC. I could even name it after the seller if I wanted to. I would just have a Out of state Party be the trustee, and make sure that the Beneficial interest was My LLC.

I might look into this a little more, as I get more houses under my belt.

Framer

Your buyer can’t take a loan out against the house and can’t demolish or rebuild. If it’s your house you’ve already made a down payment on it. You have already taken care of bank and credit qualifying when you obtained the property. Nobody said anything about fee simple real estate. Your buyer owns 50% of the trust (personal property), and can do nothing without your signature and that of your trustee.

Whatever you do, NEVER name a private individual as your Trustee, whether out of state or not. Reason:

USING A FRIEND OR RELATIVE AS TRUSTEE

Risky and quite probable failure to honor privacy and anonymity, especially under threat of legal action.

An individual trustee’s failure to charge a fee would not support the land trust’s validity in court. The attempt to charge a fee would not be seen as adequate unless the party were a bonded entity.

An individual trustee’s death would embroil the property in his/her own bankruptcy, Probate and other personal legal actions.

An individual would most likely never be bondable as a trustee and would likely not have the resources to provide a completely separate, free and bonded collection and bill-paying service.

An individual would not be seen by the courts as a standard trustee, charging fees “commensurate with industry standards”: therefore severely impairing the integrity and structure of the land trust.

One’s own personal appointment would not be seen by a 2nd or 3rd co-beneficiary as a mutually trustworthy holding entity. Such likely bias obviously would not be in the best interests of any of the co-beneficiaries.

Da Wiz

Gary

You are the one that said “Fee Simple Real Estate”.

Quote and Unquote

"Hi framer,

If the deed is in your name, that’s easy. You’ve already acquired the property, a valuable asset, now you must manage it.

You place the property into a land trust, name your trustee, and find a tenant who agrees to live in the property, make the payments and be responsible for maintenance and repairs under a triple net lease. If he will do that, you will GIVE him IMMEDIATE home ownership benefits by assigning him a 50% beneficiary int. in the trust, in exchange for a HIGHER RENT. (Retain 50% for yourself). For tax purposes, the IRS considers him an owner of the property and he is entitled to writeoff the mortgage interest and property taxes. To top it off, you agree to share future appreciation 50/50.

You’ll have a positive cash flow, your tenant sends the rent direct to your payment processing company who pays the mortgage and you just receive a check every month. If your tenant defaults, it’s always a simple eviction.

You’re in a great situation with strong asset protection in the trust, and look what you have done for your tenant:

Your Tenant/Resident Beneficiary is effectively buying a house on a seller-carry…100% percent of it.
He gets 100% of the property;

100% of the income tax write-off;
100% of the use, occupancy and possession;
100% of any water and/or mineral rights that go with the property;
100% of the right to refinance in his own name at the termination of the agreement;
100% of all the asset protection the trust provides;
100% of his down payment made by someone else;
100% of his credit qualifying done by someone else;
100% of the right to ALL the benefits of Fee Simple Real Estate ownership without credit or bank qualifying or the standard up-front cash.

The only thing he is not getting is whatever equity the non-residents (YOU)have at inception and possibly some percentage 50% of the future appreciation potential…which appreciation may never happen…in which event he’s even gotten 100% of the non-appreciation and made a great deal for himself.

As you can see, I combine my land trust “subject to” with a triple net lease and an equity share. Never look at an “Equity Share” scenario as only owning part of something: the resident owns it all, he just agrees that in exchange for his good fortune in being able to acquire a home with all of his shortcomings, he’ll happily share some of the future appreciation with his Benefactor (YOU)…but only if there is ever to be any.

You feel like Santa Claus and make a nice return on your investment with virtually no risk.

Da Wiz"

And I said out of State party not relative, it could be a Lawyer. However it could be, and historically they have been in the origins of Trusts

[i]"USING A FRIEND OR RELATIVE AS TRUSTEE

Risky and quite probable failure to honor privacy and anonymity, especially under threat of legal action."[/i]

I might think I could better judge my friends and I hope relatives than that.

“An individual would not be seen by the courts as a standard trustee, charging fees “commensurate with industry standards”: therefore severely impairing the integrity and structure of the land trust.”

Just how much is the “fee commensurate with industry standards” ? $10, $100, a Million? Is there a set fee that a Trustee must ask? What is that amount please.

"An individual would most likely never be bondable as a trustee and would likely not have the resources to provide a completely separate, free and bonded collection and bill-paying service."

an individual can not be bonded? Since when is the trustee responsible for the bills. management maybe, if spell out in the trust. And again why can I not use an individual? Maybe an out of state CPA, Attorney, and even a LSC can have individuals as the sole operators. Are attorneys not eligible as they are individuals?

Are trustees therefore usually Partnerships, or corporations, or multi partner LLC’s are are we talking hypothetically maybe siamese twins?

is a trustee supposed to be someone we do not know? Can’t be someone we might just trust?

Framer35

I find it sad when someone tries to discredit my 100% accurate post about the workings of a land trust.

You said the tenant could encumber or demolish the property – he can’t, The trustee has title to the property.

You said your tenant in a land contract can also deduct the mortgage interest and property taxes – he can, BUT you will be nailed with taxes as a land contract is considered an immediate sale. My previous post about 100% was 100% accurate.

Then you try to tell me how to select your trustee. You should not select a friend, or an attorney, or a corporation as your trustee. The land trust is an awesome strategy, BUT you must do it right. People picking their own trustees or playing games with the trust can give it a bad name.

Here is why you should only select a non-profit corporation who knows what they are doing as your trustee. Here is what is wrong with picking anyone else:

ONE’S SELF AS TRUSTEE

Risky and quite probable failure to honor privacy and anonymity, especially under threat of legal action.

An individual trustee’s failure to charge a fee would not support the land trust’s validity in court. The attempt to charge a fee would not be seen as adequate unless the party were a bonded entity.

If a trustee is also a beneficiary, a merger of title is created (see Doctrine of Merger), invalidating the trust if challenged in court as being a bona fide land trust.

An individual would most likely never be bondable as a trustee and would likely not have the resources to provide a completely separate, free and bonded collection and bill-paying service.

An individual would not be seen by the courts as a standard trustee, charging fees “commensurate with industry standards”: therefore severely impairing the integrity and structure of the land trust.

One’s own personal appointment would not be seen by a 2nd or 3rd co-beneficiary as a mutually trustworthy holding entity. Such likely bias obviously would not be in the best interests of any of the co-beneficiaries.

=========================
USING ONE’S ATTORNEY AS TRUSTEE

Using one’s own attorney would perhaps not pose a problem as long as no other unrelated beneficiaries were involved who would have separate and independent interests and financial objectives within the arrangement.

An individual trustee’s failure to charge a fee would not support the land trust’s validity in court. The attempt to charge a fee would not be seen as adequate unless the party were a bonded entity.

An attorney or law firm would most likely not be bonded as a trustee for land trusts; though his/her malpractice insurance may suffice as protection against malfeasance and/or errors and omissions.

An attorney or law firm would likely not be recognized as a bona fide trust holding institution by any court that would be challenging the integrity and purpose of a a co-beneficiary land trust title transfer.

One’s own attorney would not create a mutually trusted, unbiased third-party “escrow” entity. A biased attorney (acting in primary favor of a client) could wreak havoc in a contest involving dissention between/among beneficiaries.

USING ONE’S OWN CORPORATION

Would create a merger of title, invalidating the trust, should it be challenged in court as not being a bona fide land trust (see N.C. A.G.O. vs Russell and Dianne Barberio 2005)

A privately or closely held corporation would not charge legitimate fees and therefore would not likely be seen by the courts as a bona fide holding company, whose business it is to hold titles in trusts and charge fees commensurate with industry standards.

One’s own corporation would not be seen by a co-beneficiary as a mutually trustworthy, and wholly unbiased third-party holding (“escrow”) entity. Such a bias would not be in the best interests of co-beneficiaries. As well, using one’s own business entity would create a merger of title invalidating the land trust model.

USING AN OUTSIDE CORPORATION AS TRUSTEE

In virtually all states, any corporation used as a holding company must be either: 1) one’s own corporation (see above), 2) a chartered depository trust institution (e.g., Bank and Trust, Title and Trust, etc.) or, 3) a non-profit, charitable corporation established solely for the purpose of holding titles to real estate in trust for the benefit of its members.

The Third Party Non-Profit Corporation

A professional non-profit entity specifically and solely engaged in the holding of titles in land trusts. Fully staffed by full-time knowledgeable professionals.

A reasonable trustee fee is charged, which is well in line with industry standards is charged, enabling the creation and funding of an un-paid 3rd-party collection & disbursement entity (a free bill paying service for the benefit of members).

Cannot die (re. Probate issues), and is well backed financially to allow for careful adherence to all laws. rules and regulations relative to reporting and maintenance of a consistently good standing with the state.

Fully bonded as a trustee for title holding, beneficiary directed, 3rd party trustee nominee title-holding land trusts.

Fully recognized as a bona fide holding institution by any court that would/might be challenging the integrity and structure of the land trust or holding to adherence to statute and or standards in states wherein land trusts per se are specifically legislated and authorized

Functions a fully unbiased and unassociated third-party title holder (“escrow-type)” holding entity.

Framer35, I’m just here to help you understand how a land trust works properly. There is no reason to reinvent the wheel. The land trust is a great tool – just know what your are doing and use it properly. Good luck to you.

Da Wiz