If you have other finances available, then of course the conversation quickly changes to other factors like liability, privacy, and efficiency.

I am currently 65 yrs old and I am wondering what would be the best tax strategy to remove those 3 property's over say like a 5 yr period. 

Besides a “ hot” 3 month rental period you need a warm additional 6 months to make  above average returns.

I believe the public comment period has already passed.

In the end, you would be taking free money (cash), spending it on returns that you won't recover for almost 15 years (if all goes perfectly well), and getting charged interest on your own money when/if you decided to need that loan from him.Too many unknowns, too long recovery period for your cost, too much risk. 

Cash out refinance, unless I have a good plan to pay back the HELOC in a short period of time. 

You have to read about others' stories and how they survived during periods of struggle or epic failure. 

Just trying to learn quickly and be effective and efficient with my time, money, and resources. 

Given my portfolio is solely under me within multiple LLCs, I am not exactly sure how to efficiently structure the business to be able to allocate equity in the portfolio.

I realize I should have done all this during my due diligence period but I'm learning as I go...