Seems like a very strict penalty if this is not followed through.The CTA provides that willfully reporting or attempting to report false or fraudulent beneficial ownership, or willfully failing to report or make updates to the reported data shall be punished with a civil penalty of up to $500/day while the violation continues (up to $10,000) and a criminal penalty of up to two years in prison. 

Real estate agents are not highly regulated in Costa Rica as opposed to North America.  

That doesn’t go unnoticed by regulators.

In my experience, a property with multiple cottages and outbuildings can provide all kinds of creative strategies...some folks try short-term rentals or even specialized retreats if local regulations allow.

It’s also worth diving into local regulations and HOA rules—they can shift quickly in coastal markets like this.

This is a complicated situation with multiple layers to consider, so here’s my take based on your questions:If you’re looking to move assets from the partnership into individual LP (Limited Partner) names while avoiding capital gains, you’ll need a strategy that complies with tax regulations.

Let's check the Regulations 1.21-1 which clarify Section 21.

However, too many risks with that, and too many regulations I guess...

For sure it is a huge safetly net if you can get it, but strictly applied, seems many of us would be out of business.

Looking forward to the journey ahead....In my experience, very few properties in Ohio are strictly required to operate as Section 8 rentals.