My father in law was an IRS Revenue Agent. His quip was that about 20-30% of the civilian economy has tax avoidance as a primary business objective. Real estate is probably the greatest example.
Since financial engineering is in many ways more essential than the actual business. His best example was a chain hotel. In the majority of cases, a typical hotel is a tax vehicle that happens to rent rooms. So no wonder everything becomes a bank. :)
A typical chain hotel (by which I assume you mean a Marriott/Hyatt/Hilton/IHG/Choice/etc brand) is a franchised “small” business.
The franchisee typically pays 10% to 20% royalty to the franchisor (the aforementioned companies). Otherwise, they rent hotel rooms and pay staff to clean them and rent them again.
What is the tax play? That the hotel owner can 1031 into bigger and better hotels? Anyone who owns real estate can do that.
Well, one could argue the entire setup is a means of structuring investments and organizing/attracting Capital eh?
Hotel owner (aka franchisee) puts in capital in a specific way under license, gets help operating it, in exchange for the 10-20% licensing fee paid back to the main corporation.
In many cases, the owner/operator is nearly turnkey, and it’s an effective way of setting up a defacto managed business investment, almost like a LP. Many of the franchised hotels are actually owned/operated by LPs setup for the purpose.
Also in many of these cases, the franchiser provides contacts for financing, may directly facilitate/recruit Capital, and may even provide loans to the franchisee directly.
For most of these larger hotels, the actual act of renting out rooms, etc. is pretty much all automated/managed through the central system anyway, and the majority of the operating costs are structured in such a way as to minimize tax liability.
Not at all. The poster I responded to claimed this:
> a typical hotel is a tax vehicle that happens to rent rooms.
>In many cases, the owner/operator is nearly turnkey,
What does this even mean? Hotels can be turnkey, which in industry terminology means that everything is working sufficiently well such that you can start renting rooms immediately. An owner/operator being turnkey makes no sense.
> setting up a defacto managed business investment
Also makes no sense.
>Also in many of these cases, the franchiser provides contacts for financing, may directly facilitate/recruit Capital, and may even provide loans to the franchisee directly.
Even if true, what does this have to do with taxes?
>For most of these larger hotels, the actual act of renting out rooms, etc. is pretty much all automated/managed through the central system anyway,
No, the actual out of renting out rooms involves housekeepers, maintenance staff, guest service agents, cooks, and management making sure rooms are clean and habitable. Reserving a hotel room is mostly automated, but even that requires a person to manage conflicts of reservations (e.g. unexpectedly needing to extend a stay causing overbooking, changing room types, room locations, etc.)
>and the majority of the operating costs are structured in such a way as to minimize tax liability.
Who doesn't structure their operating costs to minimize their tax liability? If you file married joint instead of married separate or head of household, are you "structuring" your operating costs as a way to minimize tax liability?
The question of how a hotel is used to gain an tax advantage that would otherwise be unavailable remains unanswered.
Most properties are syndicated. Hotels are interesting because they are mix of different asset types. The GP operates the place and LPs contribute capital. Accelerated and bonus depreciation passthrough to the LPs entity.
And how is a hotel a mix of different asset types?
What does GPs and LPs have anything to do with using a hotel to gain a special tax advantage that is not available to any other commercial real estate?
Can you give examples? I thought becoming a bank in the US is famously difficult and regulated, so much so that most businesses who can avoid it do so by partnering up with existing, tiny banks. See almost any “fintech” solution, from startups all the way up to Apple.
As far as I understand, becoming a bank is inviting a ton of overhead with little profit potential.
I don’t think they meant a literal bank, but finance games become a bigger part of their core strategy. For example, AirBnB for a while made a majority of its profits by investing the money guests paid during the gap between booking and actual stay (paying the host).
Since financial engineering is in many ways more essential than the actual business. His best example was a chain hotel. In the majority of cases, a typical hotel is a tax vehicle that happens to rent rooms. So no wonder everything becomes a bank. :)