o The co-owners can't operate as a partnership or business entity or file a partnership or corporate tax return.

o Co-owners retain the right to approve the hiring of any manager, the sale or disposition of the property and any leases.

o In general, each co-owner must have the rights to transfer his undivided interest without the agreement or approval of any person.

Mary B. Foster, general counsel for Section 1031 Services Inc., a qualified intermediary in Bellevue, Wash., says the IRS hasn't released any rulings yet on specific TICs, although some sponsors have gotten rulings that haven't been published yet.

TICs may make sense for some buyers, particularly if it's a good property, she says. But investors need to look at upfront fees, which can be significant-as much as 15% to 25% of the initial investment, she says. Also, returns quoted often incorporate the tax deferral an investor would get by doing a 1031 exchange, Foster adds.

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