<p>Last week we heard a chorus of voices from around the web urging the preservation of like-kind exchanges in any forthcoming tax reform. Graniterock CFO Steve Snodgrass characterized the unprecedented cross-industry support this way:&nbsp; "Rarely do the interests of small businesses owners, construction equipment intensive businesses and a broad range of local entrepreneurs agree with almost a century of federal income tax policy — especially when it results in billions of dollars in taxes being paid. But fortunately for the economy, they do."</p>

<p><a href="https://chicagoagentmagazine.com/2017/06/23/trump-tax-plan-targets-loop…; target="_blank">Trump tax plan targets loophole that spurs property investment, critics say</a> – <i>Chicago Agent Magazine</i></p>

<p><a href="http://www.bizjournals.com/stlouis/news/2017/06/23/commentary-help-the-…; target="_blank">Commentary: Help the American economy: Keep the like-kind exchange</a> – <i>St. Louis Business Journal</i></p>

<p><a href="http://www.santacruzsentinel.com/opinion/20170617/steve-snodgrass-encou…; target="_blank">Steve Snodgrass: Encouraging small business growth — and paying taxes</a> – <i>Santa Cruz Sentinel</i></p>

<p><a href="http://www.hotelmanagement.net/transactions/potential-end-1031-exchange…; target="_blank">Potential end of 1031 exchange provision could impact hotel transactions</a> – <i>Hotel Management</i></p>

<p><a href="https://therealdeal.com/2017/06/13/popular-re-tax-break-1031-exchange-m…; target="_blank">Popular RE tax break 1031 exchange may be wiped out</a> – <i>The Real Deal</i></p>

<h2>Creation of the Role of Qualified Intermediary in the Treasury Regulations</h2>

<p>Prior to the Internal Revenue Code Section 1031 Treasury Regulations issued in 1991 governing exchanges, it was difficult to arrange for the taxpayer’s buyer to actively participate in the taxpayer’s exchange transaction. It could not be accomplished without the buyer’s significant involvement. However, buyers were not typically motivated to assist in the seller’s attempt at tax deferral. The 1991 regulations sought to deal with this thorny problem by creating a new entity known as a <a href="https://www.accruit.com/about-us/how-choose-qualified-intermediary">qua… intermediary (QI)</a>.</p>

<p>The QI would serve as an intermediary to whom the taxpayer’s relinquished property would be transferred, and from whom it would be transferred to the taxpayer’s buyer. Additionally, the QI would acquire replacement property from a seller and transfer it to the taxpayer. Hence, the taxpayer would not do an exchange with a buyer or seller but with the QI. Since both relinquished and replacement properties passed between the taxpayer and QI, the QI was referred to as an “intermediary,” but what makes the Intermediary <i>qualified</i>?</p>

<h2>Persons Disqualified to Act as Intermediary</h2>

<p>To answer this, it is helpful to review the regulations to see what persons are specifically not qualified to facilitate an exchange. Anyone who is not disqualified should then be considered qualified. Also, it should be noted that, although in these regulations (and the Tax Code) there are references to <i>persons, </i>that term is also deemed to refer to other entities, as well. In general, an agent or related party of the taxpayer is disqualified. The regulations state:</p>

<blockquote>
<p style="margin-bottom:.0001pt">“The person is the agent of the taxpayer at the time of the transaction. For this purpose,a person who has acted as the taxpayer's employee, attorney, accountant, investment banker or broker, or real estate agent or broker within the 2-year period ending on the date of the transfer of the first of the relinquished properties is treated as an agent of the taxpayer at the time of the transaction”</p>
</blockquote>

<p>If any of this group of persons provided services within two years of the sale of the relinquished property, that person (or entity) is disqualified. There are several exceptions, and the primary one pertains to financial institutions. This exception applies where the entity has provided “routine financial, title insurance, escrow, or trust services for the taxpayer by a financial institution, title insurance company, or escrow company.” So, for example, a company who provides routine banking services or escrow services can still be qualified to act under these rules.</p>

<h2>Related Parties as Qualified Intermediaries</h2>

<p>As for having a related party act as the QI in an exchange, the rules make reference to code sections 267(b) and 707(b). The rules in these code sections apply specifically to a taxpayer wishing to buy replacement property from an individual or entity to whom the taxpayer is related, however the disqualified person rules borrow from these provisions. I address the specifics of the related party rules in <a href="/blog/1031-tax-deferred-exchanges-between-related-parties">"1031 Tax Deferred Exchanges Between Related Parties."</a></p>

<p>The related party rules primarily disallow a person from acting as QI if they are a familial relation to the taxpayer. With regard to entities in which the taxpayer may have an ownership interest, the related party rules provide that a greater than a 50% interest between the taxpayer and a replacement property seller will cause the transaction to be disallowed. For instance, if taxpayer A wished to buy his replacement property from a two-member LLC of which A and B were equal members, the transaction would be allowed since A does not have a <i>greater than 50%</i> interest in the LLC. Not so if A has a greater than 50% interest.</p>

<p>The disqualified person rules mirror the related party rules with one significant difference. For the disqualified person rules, the 50% interest rule is reduced to 10%. So, in the example above, because A has a membership interest of greater than 10%, he could not serve as a QI.</p>

<h2>Additional Exchange Company Roles</h2>

<p>Although here I am specifically addressing persons disqualified from acting as qualified intermediaries, it should be noted that there are similar roles that may also be serviced by an exchange company, from which such persons would be similarly disqualified. These roles include those of qualified escrow agent, trustee of a qualified trust and, for reverse 1031 exchanges, exchange accommodation titleholder. Acting in any one of these capacities would require that the service provider not be a disqualified person.</p>

<h2>Conclusion</h2>

<p>In summary, to act as a qualified intermediary a person or entity must not be a <i>disqualified person</i> under the applicable regulations. Persons who are agents of the taxpayer, defined as having done work for the taxpayer during the prior two-year period, are disqualified. This rule does not apply if the service provided has merely consisted of routine financial services during that period.</p>

<p>Additionally, a related party cannot provide QI services if that party is one of enumerated types of relations to the taxpayer or if the taxpayer has an interest in the service provider greater than 10%. Finally, if a person is not disqualified, then the person is qualified.</p>

<p>For more information on this or other 1031 topics, contact me today.</p>

<p>(312) 207-1031<br />
martine@accruit.com</p>

<p style="margin-left:.5in">&nbsp;</p>

<p>The results of the recent election cycle will have a profound effect on the United States income tax system.&nbsp; With Republican control over both chambers of Congress and the Oval Office, we can expect bold moves in tax reform—bold, but not unexpected.&nbsp; In anticipation of a reform-friendly environment, the House Republicans, prior to the November elections, released an outline for future tax reform.&nbsp; Released on June 24, 2016 and titled, “A Better Way, Our Vision for a Confident America,” the document is the foundation for the Republican’s tax reform efforts.&nbsp; The outline is also referred to as the “House Republican Blueprint” (HRB), and while only 35 pages in length, it seeks to begin a “conversation about how to fix our broken tax code.”</p>

<p>While few can accurately predict the outcomes of 2017 tax reform, the consensus view is that corporate tax rates will be reduced from current levels. While the timelines and the degree of these reductions are unknown, savvy CFOs are recognizing opportunity in the face of this uncertainty. Many tax advisors are looking at ways to defer current taxation to a post-tax reform future with a lower rate and a more favorable environment. This “tax arbitrage” situation might very well result in permanent deferrals and once-in-a-lifetime opportunities for businesses.</p>

<h2>Two Potential Tax Reform Plans</h2>

<p>Here is a brief look at two of the tax reform plans that have been talked about:</p>

<p><strong>The House Republican Blueprint – Tax Rate Details </strong></p>

<p>The HRB looks to change income tax rates in the following ways:</p>

<ul>
<li>Individuals – Reducing tax brackets from seven to three, with a top bracket of 33% as opposed to the current 39.6%.&nbsp; Alternative minimum tax (AMT) would be repealed.</li>
<li>Sole proprietors and pass-through entities – For active business income, tax rate would be capped at 25%.&nbsp; Currently, this income passes through the entity and is reported by the owner(s) and taxed at the owner’s rate(s).&nbsp; In some cases, the owner’s rates can exceed 40%.</li>
<li>C-corporations – taxed at a single rate of 20% and a complete repeal of the alternative minimum tax.&nbsp; Currently, these rates can be as high as 39%.</li>
</ul>

<p>While the rate cuts are significant, they are but a small sample of the overall HRB.&nbsp;</p>

<p><strong>Donald J. Trump’s Plan – Tax Rate Details</strong></p>

<p>Since tax reform will require cooperation with the president, here is a review of some highlights from President Donald Trump’s tax proposal:</p>

<ul>
<li>Individuals – Similar to the HRB with a reduction from seven tax brackets to three and the same reductions in tax rates as the HRB.</li>
<li>C-corporations – Tax rate would drop from 35% to 15%, and the alternative minimum tax would be eliminated.</li>
</ul>

<h2>An Opportunity for Owners of Heavy Equipment</h2>

<p>With both proposals, it’s plain to see that lower tax rates are most certainly on the horizon.&nbsp; For owners of heavy equipment, lower rates offer a chance to conduct a like-kind exchange within a high tax environment to defer income taxation into a lower tax environment.&nbsp;</p>

<p>Recognizing gains in a lower tax environment, often referred to as tax arbitrage, takes advantage of an opportunity for sellers of personal property to permanently reduce income tax through changing tax laws.</p>

<p>Let’s look at an example where the taxpayer sells equipment in a high tax environment, conducts a like-kind exchange, and effectively defers $18,824 of income taxation.</p>

<p>Then, in a future (lower tax) environment, that same taxpayer sells the replacement equipment without conducting another like-kind exchange.&nbsp; Instead, the equipment owner chooses to recognize the sale’s income as a taxable event.&nbsp; For simplicity’s sake, let’s use the same sales and depreciation figures used above.</p>

<p>The advantage of combining the deferral benefits of like-kind exchanges with an arbitrage strategy is clear.&nbsp; The equipment owner’s recognition of income in a 20% tax rate environment permanently saves the owner $9,412 in taxation – the difference between the 40% and 20% tax rates.</p>

<h2>Summary</h2>

<p>New tax arbitrage opportunities are good news for equipment owners who take the initiative to carefully engage with their tax advisors and qualified intermediary to ensure their goals are met and that the planning process fits squarely within the parameters of the law. With proper planning, 2017 tax reform could present your business with a rare opportunity.</p>

<p>For more on 2017 tax reform or if you’d like additional information on tax arbitrage opportunities, contact us today.</p>

<p>(866) 397-1031<br />
&nbsp;</p>

<h2>Taxable Boot Related to Prepaid Rent and Security Deposits</h2>

<p>In a standard closing (not involving a 1031 exchange), it is typical for the prepaid rent and security deposits being held by the seller to be treated as a credit to the buyer at closing.&nbsp; In that context, the net amount paid to the seller for the property at closing is simply reduced.&nbsp; However, this same practice in connection with a sale of relinquished property in a 1031 exchange <a href="/blog/avoiding-cash-boot-1031-real-estate-exchange">will inadvertently result in boot</a>, and the amount of prepaid rent and security deposits retained the by taxpayer will be taxable.</p>

<p>This happens quite frequently in exchange transactions and the taxpayer and his advisors are unwittingly subjecting the taxpayer to taxable gain.&nbsp; Rent and security deposits are income items and cannot be offset against gain otherwise recognized in an exchange.</p>

<h2>Let’s Look at an Example</h2>

<p>Take the case of a taxpayer selling a multi-family apartment building for $500,000.&nbsp; Let’s assume he is holding $20,000 in rent he received representing the balance of days in the month where the buyer is actually in ownership of the property (prepaid rent).&nbsp; Let’s also assume that the total of security deposits held by the taxpayer is $25,000.&nbsp; So the taxpayer has a total of $45,000 of cash in his pocket.&nbsp; Let’s also assume for the sake of simplicity that the property has no mortgage and nominal closing costs.&nbsp;</p>

<p>If the taxpayer gives a credit to the buyer for this $45,000 amount, the net value received for the property would be $455,000.&nbsp; However, this is problematic in a 1031 exchange as the $45,000 cannot be offset against gain and any boot will be taxable. To avoid taxable boot the taxpayer would have to buy replacement property equal to or greater than the net value, in this case $500,000, without the offset of the prepaid rent and security deposits.</p>

<h2>How Is this Problem Corrected?</h2>

<p>In a closing involving a 1031 exchange, preparers of settlement statements should ignore the customary practice of providing credits for rent and security deposits. Rather, the taxpayer should transfer those income items directly to the buyer.</p>

<p>Using the example above, with rent and security credits paid directly to the buyer, the net sale price of the apartment building would be $500,000 and if the taxpayer traded up or even for replacement property, there would be no boot.</p>

<h2>Do Real Estate Taxes Credited to a Buyer Result in the Same Issue?</h2>

<p>Real estate taxes are looked at a bit differently.&nbsp; Generally at a closing, the seller will give the buyer a credit for taxes that have accrued while the seller was in ownership but which are not yet due and payable.&nbsp; The payment of real estate taxes generally are billed and paid in arrears.&nbsp; So the taxpayer has not received income on that sum, rather it is a liability of the property.&nbsp;</p>

<p>The treatment of the real estate tax liability is similar to the way debt (mortgage) is treated.&nbsp; Under exchange rules, any debt paid off upon the sale of a property must be replaced by new debt on the replacement property in an equal or greater amount.&nbsp; "Relief” of real estate tax liability due to a credit of that amount to the buyer can be offset by equal or greater tax liability the taxpayer may receive from the seller of the replacement property.</p>

<h2>Are These Same Considerations Relevant to the Replacement Property Closing?</h2>

<p>Similar issues arise when there are credits to the taxpayer at closing.&nbsp; Credit that the taxpayer receives for these items will be treated as taxable cash boot.&nbsp; Again, a credit given to the taxpayer will reduce the amount that the taxpayer pays to buy the property, however a check directly from the seller to the taxpayer for these amounts avoids the result of taxable boot.&nbsp; In the event a credit is given, the rent is treated as rental income.&nbsp; The security deposit amount is not characterized as income since it is being held for return to the tenant upon conclusion of the lease.</p>

<h2>Summary</h2>

<p>It is customary for a seller to give the buyer a credit for the prepaid rent and the security deposits in a non-exchange sale of property. This causes no special issues.&nbsp; In a closing involving a <a href="https://www.accruit.com/property-owners/1031-exchange-explained&quot; title="1031 tax deferred exchange">1031 tax deferred exchange</a>, this same practice will result in taxable boot to the taxpayer.&nbsp; The way to avoid this outcome is for the seller/taxpayer to pay the amount of these credits directly to the buyer outside of the closing. &nbsp;Taxable boot may also result when the taxpayer acquires replacement property and receives credits.&nbsp; Again, those sums can be paid directly from the seller to the buyer in order to avoid any boot.</p>

<hr />
<p>&nbsp;</p>
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<h2>Converting a C Corporation to an S Corporation</h2>

<p>Thinking about changing your corporate structure from a C corporation to a subchapter S corporation?&nbsp; S corporations, partnerships, and certain LLCs are considered pass-through entities, which means they "pass through" various types of taxable income: interest, dividends, deductions, and credits to the shareholders, partners, or members responsible for paying tax. This avoids the double taxation associated with C corporations that pay entity-level taxes and then distribute dividends that become subject to individual taxes.</p>

<h2>What is Built-in Gains Tax?</h2>

<p>With all of the tax advantages provided to S corporations, many companies are making the move.&nbsp; However, there are some pitfalls.&nbsp; One of these is the tax recognition of built-in gains (BIG). Generally, BIG tax is triggered when existing assets are sold during the holding period, a period after the conversion to S corporation status. The holding period is currently 10 years, starting from the date of the conversion.&nbsp; During this period, the existing assets are encumbered by the corporate tax rate of 35%.&nbsp;&nbsp;&nbsp;&nbsp;</p>

<p>For ESOP companies contemplating the conversion from C Corporation to S Corporation, one of the factors to consider is that stock-option purchases generated by employee participation in an ESOP are also subject to the IRC Section 1374 – Built-In Gains (BIG) Tax.</p>

<h2>Holding Periods for Built-in Gains Tax</h2>

<p>When it comes to tax law, Congress has a habit of letting certain provisions expire, only to extend/amend them in later tax years.&nbsp; Built-in gains are no exception:</p>

<ul>
<li>For 2009 and 2010, Congress shortened the holding period to seven years.&nbsp;</li>
<li>In 2011 through 2013, the holding period was further shortened to five years.&nbsp;</li>
<li>For 2014 and 2015, the holding period is 10 years.</li>
</ul>

<p>The shorter holding periods of prior years proved beneficial for a great number of companies that were concerned about the traditionally long (10 year) holding period, helping many avoid recognizing gains at a punishing 35%.</p>

<h2>Disposing of Assets during the Built in Gains Holding Period with a 1031 Exchange</h2>

<p>In the ordinary course of business, companies may need to dispose of existing assets, whether those assets are underutilized, aging fleets, idle or obsolete equipment, or rental assets routinely sold and replaced. Holding on to such assets takes up yard space and triggers unnecessary insurance costs and maintenance fees.&nbsp; Exchanging them through a Section 1031 like-kind exchange (LKE) will protect those built in gains from income recognition (taxation), free up working capital, and significantly increase cash flow to continue growing and expanding operations.</p>

<h2>Beyond the Holding Period: The Like-Kind Exchange Program</h2>

<p>Implementing a 1031 exchange will not only keep the BIG tax at bay, it can reduce or eliminate other holding costs and secure tax benefits beyond the holding period.&nbsp; It is a little bit like having your cake and eating it too.&nbsp; Asset owners that maintain an LKE program throughout the holding period can permanently avoid the pain of BIG tax and implement a business process that protects them from triggering taxation after the holding period ends.&nbsp;</p>

<p>Absent an ongoing like-kind exchange program, future sales will likely be subject to income taxation (flowing out to S Corp owners).&nbsp; Leveraging a 1031 like-kind exchange program immediately after the conversion provides tremendous cash flow opportunities, as does keeping the program in place thereafter.&nbsp;</p>

<h2>Summary</h2>

<p>Asset owners, with recent C to S corporation conversions should evaluate their tax positions with their advisors, and consider the potential negative impact of their built-in gains.&nbsp; With the help of a qualified intermediary, owners can project the returns that like-kind exchanges can generate by allowing access to a low cost of capital, deferring gain recognition, and ensuring that their BIG will never get small.<br />
<br />
<a href="/contact-us">Contact us</a> for a free consultation.</p>

<p>During his campaign, President-elect Trump was criticized for the non-release of income tax returns.&nbsp; The information available is limited to his own statements and the release of three pages from his 1995 returns of income from New York and New Jersey.&nbsp; These pages reveal what amounts to a $900M loss.&nbsp; Unfortunately, these documents are driving misstatements and generating misleading information related to Section 1031 Like-Kind Exchanges – one of the real estate industry’s most popular tax strategies</p>

<p>Misstatements and Misleading Information about 1031 Like-Kind Exchanges</p>

<p>Several articles framed like-kind exchanges in a negative light, including:</p>

<ul>
<li><a href="http://r20.rs6.net/tn.jsp?f=001kO1MibvhX-jGOl_vH8ILV0RlPt2BIPI0a2GeXhCx…; target="_blank"><em>The New York Times: "How Donald Trump Turned the Tax Code Into a Giant Tax Shelter," by James B. Stewart, October 2, 2016</em></a></li>
<li><a href="http://r20.rs6.net/tn.jsp?f=001kO1MibvhX-jGOl_vH8ILV0RlPt2BIPI0a2GeXhCx…; target="_blank"><em>Washington Post: "How Donald Trump and other real-estate developers pay almost nothing in taxes," by Max Ehrenfreund, October 4, 2016</em></a></li>
<li><a href="http://r20.rs6.net/tn.jsp?f=001kO1MibvhX-jGOl_vH8ILV0RlPt2BIPI0a2GeXhCx…; target="_blank"><em>PBS Making Sen$e: "The tax rules that let real estate moguls like Trump pay no federal income tax," by Steven M. Rosenthal, October 3, 2016</em></a></li>
<li><a href="http://r20.rs6.net/tn.jsp?f=001kO1MibvhX-jGOl_vH8ILV0RlPt2BIPI0a2GeXhCx…; target="_blank"><em>Tax Policy Center: "Does Donald Trump pay taxes, ever?" By Steven M. Rosenthal, October 3, 2016</em></a></li>
<li><a href="http://r20.rs6.net/tn.jsp?f=001kO1MibvhX-jGOl_vH8ILV0RlPt2BIPI0a2GeXhCx…; target="_blank"><em>USA Today: "Fact check: Spinning Trump's taxes," by Eugene Kiely and Robert Farley, FactCheck.org, October 3, 2016&nbsp;</em></a></li>
<li><a href="http://r20.rs6.net/tn.jsp?f=001kO1MibvhX-jGOl_vH8ILV0RlPt2BIPI0a2GeXhCx…; target="_blank"><em>USA Today: "Trumping Real Estate Taxes: Our View," USA Today Editorial Board, October 5, 2016</em></a></li>
</ul>

<p>Beyond the tone of these article, there’s specific information that deserve attention:</p>

<h2>Like-Kind Exchanges – Not a Sweet Deal for Developers</h2>

<p>Section 1031’s introductory&nbsp; paragraph clearly states, “No gain or loss shall be recognized on the exchange of property held for productive use in a trade or business or for investment if such property is exchanged solely for property of like kind which is to be held either for productive use in a trade or business or for investment.” The second paragraph moves into more detail, plainly declaring that stock in trade and <strong>other property held primarily for sale</strong> is disqualified from like-kind exchange treatment.&nbsp; It couldn’t be any clearer.&nbsp; Inventory <strong>does not</strong> <strong>qualify</strong> for Section 1031 treatment, and given that developers primarily deal in inventory, most of what they produce is disqualified under Section 1031.&nbsp; A simple investigation into the first 83 words of Section 1031 provides the reader with a basic understanding of the developerversus investor issue.</p>

<h2>Comparisons between Like-Kind Exchanges and Stocks and Bonds</h2>

<p>Like-kind exchanges are sometimes criticized for their application to business use property and other investment property, but not for stocks and bonds. In doing so, critics have suggested that well-off real estate investors receive special and favorable treatment, treatment not available to the wider investing public.&nbsp; While it is true that Section 1031 specifically excludes stocks and bonds from like-kind exchange treatment, the comparison is fundamentally misleading.&nbsp; &nbsp;</p>

<p>One of Section 1031’s original goals was to encourage the exchange of similar illiquid assets without significantly diminishing the net worth of the taxpayer. In promoting the sale and purchase of certain assets, Section 1031 encourages capital formation by discouraging the lock-in effect (the incentive to hold on to property) that taxation promotes. By specifically <strong>excluding</strong> stocks and bonds, Section 1031 can focus on supporting the sale and purchase of some of the largest and most valuable assets in the country.&nbsp;</p>

<p>It’s important to note that <a href="/blog/1031s-build-america">the disposition and acquisition of these types of assets employ thousands of United States taxpayers</a>, in both private and governmental roles.&nbsp; Blue collar and white collar workers all benefit from the movement of real estate.&nbsp; Real estate transactions move people into wage-earning action, allowing them to feed their families, pay their mortgages, and purchase goods and services.&nbsp; All of these activities generate the payment of taxes from the salaries they earn.&nbsp;</p>

<p>In comparison, stocks and bonds are often easily and readily transferable through the open market and do not typically suffer from the same type of lock-in effect.&nbsp; Securities often possess inherent liquidity through various, ever-changing market pressures.</p>

<h2>Section 1031 is not a Loophole for Real Estate Holders</h2>

<p><a href="http://www.dictionary.com/browse/tax-loophole?s=t&quot; target="_blank">A tax loophole is defined as</a>, “A provision in the laws governing taxation that allows people to reduce their taxes. The term has the connotation of an unintentional omission or obscurity in the law that allows the reduction of tax liability to a point below that intended by the framers of the law.”</p>

<p>Like-kind exchanges have been part of U.S. tax law for nearly 100 years.&nbsp; During this period, the tax code has not only survived but has been refined through congressional review and numerous court cases.&nbsp; At its core, Section 1031 speaks directly to its underlying theory - continuity of investment.&nbsp; Continuity of investment dictates no recognition of tax as long as exchanging taxpayers followed the law, didn’t cash out, and reinvested in similar (like-kind) property.&nbsp; From its beginnings, the framers of the law held this theory as central to its creation.&nbsp;</p>

<p>It is worth noting, a full 33% of like-kind exchanges involving real estate trigger some income tax and the vast majority (88%) of real estate exchanges result in a future taxable disposition of the replacement property.</p>

<h2>Section 1031 is Fair for the American Taxpayer</h2>

<p>Section 1031 is equitable tax policy.&nbsp; It has survived for nearly 100 years by empowering taxpayers across income levels and in a wide variety of businesses to efficiently leverage their investments to build wealth and create jobs.&nbsp; It’s a process that has been good for investors, good for the economy and good for the United States Treasury.&nbsp; With the election over and talk of tax reform heating up, please remember to be wary of statements intended to evoke emotional responses.&nbsp; More often than not, some careful research will yield more accurate information.</p>

<p>&nbsp;</p>

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