Overview
Sponsors who treat tax planning and debt placement as separate workstreams leave 50 to 200 basis points of after-tax IRR on the table. This hub aggregates the capital-stack tax-crossover pillar, the coordination matrix, sibling Q&As, and the IRS-anchored glossary terms.
Why this matters
A §1031 exchange that fails because the replacement loan didn't close inside the 180-day window converts a tax-deferred sale into an immediately taxable one. A QOF construction loan that drifts past a six-month testing date threatens the QOF's 90% asset compliance.
Sponsor coordination of tax counsel, lender, and equity timing is what produces clean executions. Most after-tax-IRR slippage comes from placement-team and tax-team conversations that never happened.
How to use this hub
Start with the pillar for the framework across §1031, OZ/QOF, cost-seg, UBTI, and C-PACE. Use the CRE §1031 debt-replacement calculator whenever a relinquished property carries debt; it sizes the minimum replacement loan needed to avoid mortgage boot. Drop into the Q&A library for specific mechanics and the glossary for IRS terminology.
This hub is sponsor-POV process commentary, not tax or legal advice. Bring a CPA and tax counsel onto every transaction.
Pillar guide
Sponsor-side tool
Sibling Q&As
How does a §1031 exchange coordinate with CRE loan and debt timing?
Coordinating a §1031 like-kind exchange with new CRE debt requires aligning the 45-day identification window, the 180-day completion deadline.
How does CRE debt fit inside an Opportunity Zone (QOZ) capital structure?
QOZ projects raise equity from Qualified Opportunity Funds and layer construction or bridge debt at the QOZB level.
Does a cost segregation study affect CRE loan sizing or DSCR?
A cost segregation study reclassifies building components into shorter-life depreciation categories. Lenders ignore the study for DSCR sizing but borrowers see.
How does bonus depreciation change the cash-on-cash math on a CRE deal?
Bonus depreciation accelerates first-year deductions on 5/7/15-year property. Combined with cost segregation, it can shelter most of year-one cash flow from tax.
Cash-out refinance vs. §1031 exchange: which defers tax better for a CRE owner?
Cash-out refinance produces tax-free proceeds at refi without a triggering sale; §1031 exchange defers gain on a sale into a replacement property.
How does UBTI affect tax-exempt LPs investing in leveraged CRE?
Pension funds, endowments, and IRAs face unrelated business taxable income (UBTI) on debt-financed CRE income.
How is C-PACE financing treated for tax purposes and how does it interact with senior CRE debt?
C-PACE financing is a special property tax assessment, not a loan. The assessment is generally deductible like other property taxes.
Glossary
§1031 like-kind exchange
Mortgage boot
Qualified opportunity fund (QOF)
Cost segregation study
Bonus depreciation
Depreciation recapture
UBTI
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