QI is telling my friend (buyer) this would not constitute a taxable boot as the money is not guaranteed to the buyer. 

Whats the actual treatment plan and guarantee?

It’s also much better if any loans taken out by the LLC are NOT personally guaranteed by the member/manager of the LLC., although this is often not possible.  

No guarantee there though. 

But at least our clients know when we charge them for something, the work is needed, done right, and guaranteed.

@Michael Bishay your biggest challenge will be getting your expected ROI out of Class C & D properties.S8 vouchers aren't necessarily a guaranteed solution. 

The higher and rents that section it provides are not always guaranteed and are a reflection of the tenant's income.I'm more than happy to connect and talk about this deal further if you would like.

I apologize for the delay and I hope your deal went smoothly.William, the only way I see that being possible to get someone to lend is if you have very strong contingencies for the return of EMD that stretch the full term of the contract, as well as a personal guarantee on the loan amount. 

VA construction loans, the VA does guarantee loans to buy and renovate existing property.

It's no guarantee but it's a good place to start.