Looking for Tax/Legal Advice related to Syndications and 1039

[Don Owens]

I am looking for an individual or firm with experience setting up syndication structures with a focus on maximizing tax savings benefits for high income LPs that are participating in the fund. The fund would include primarily highly compensated director and C-level executives that are in the upper income tax brackets and are not real-estate professionals. These individuals are looking for a way to participate in more of the tax saving that come from owning property verses just getting a fixed return on hard money that is taxed as income at 30-40% when they get paid. One key question I have is around wether or how bonus deprecation write offs can be leveraged by the LPs in the fund? I would as like to better understand how taxes would be assessed post the sale of properties held by the fund for more than one year. Finally, if the LPs in the fund wanted to make use of the 1039 exchange to defer taxes on gains from the fund is that something I can do for them via the fund itself or does each individual need to do a 1039 based on their individual gains from the fund/LLC? Finally, as far business entity structure is concerned, where tax efficiency for the LPs is one of the key selling points, is there an advantage or preference for LLC, verse S-corp, verse C-corp? Thank you in advance for any recommendations or connections anyone can share that have experience in these areas.