Syndication Reporting IssuesMissing Form 8918 for reportable transactionsInconsistent investor disclosuresRequired registrations skippedWhat Doesn't Actually Matter:(Despite What Your Uncle's CPA Says)Special AllocationsNormal promote structuresStandard waterfall provisionsTypical developer promotesReality: Unless extremely aggressive, IRS rarely caresTechnical DocumentationMinor §704(b) gapsCapital account glitchesTechnical allocation languageTruth: Unless hiding something biggerProperty Value AllocationsNormal basis step-upsTypical appreciation splitsStandard promote calculationsReal World Example:🏢 100-unit apartment complex4 partners, $5M dealDeveloper promote structure= Zero IRS interestSame Deal With Red Flags:🏢 100-unit apartment complexHidden partner arrangementsArtificial loss allocationsUnreported debt shifts= IRS AttentionPractical Protection Steps:Basic Documentation✅ Clean operating agreement✅ Economic substance✅ Partner contributions tracked(Don't need War & Peace complexity)Economic Reality✅ Allocations match economics✅ Real money movement✅ Actual partner participationClean Reporting✅ Consistent K-1s✅ Required forms filed✅ Clear communicationThe "Sleep Well" Test:Can you explain your structure to an IRS agent without sweating?

I've done BRRRRs in Milwaukee for almost 15 years, but things have changed around 2020: I have a hard time buying quality properties where I get a discount that even matches rehab cost. 

The loss of priceless art, jewelry, autos, memorabilia and watches could often match or exceed the property values.

My occupancy rate is probably as good as anyone, and one thing I do is never have a high debt load then turn that around and award my tenants with rental rates they can't match elsewhere. 

AJ Dicarlo Rate (broker and will be able to match with multiple lenders instead of a smaller bank or network)

There are a lot of great resources here and around the web for people looking to invest in Birmingham.

At that time I'll attempt to structure a 10 year term unless I consider a shorter hold period in which I'll negotiate the lowest rate possible to fit a shorter term more closely matching my remaing hold timeline.

https://www.biggerpockets.com/agent/match Check it out.

You are right about dark web exposure.

Once again, this matches my personal experience that the larger, more expensive properties continue to sell better than smaller properties.