What surfaced as deduction
Portfolio mix
Net cash flow · trailing 12
The fleet
| Property | Type | Market | Value | Equity | Net / mo | Held in | Cost-seg |
|---|
STR loophole engine
Active income offset
Qualification tests
Depreciation timeline
Recapture & the catch
Show the math · statute & gates
land = P·l reclass = P·s B = P − land − reclass
year-1 = reclass + B/39 (mid-month convention omitted — flagged simplification)
qualifies = (avg stay ≤ 7) ∧ (material participation) ∧ (personal use ≤ 14)
saved = qualifies ? year-1 · r : suspended recapture ≈ up to reclass · r
Basis. §469 passive default; Reg. §1.469-1T(e)(3)(ii)(A) removes a ≤7-day-average-stay activity from “rental” (the ≤30-day + significant-services path (B) is not modeled — it surfaces as the alternative). Material participation per Reg. §1.469-5T(a) tests 1 & 3; spouse hours count (§469(h)(5)); investor-type work excluded (§1.469-5T(f)(2)(ii)). Personal use over the greater of 14 days / 10% triggers §280A(d). 100% bonus under §168(k) (OBBBA) for property acquired and placed in service after 2025-01-19 (IRS Notice 2026-11). Recapture: §1245 ordinary; unrecaptured §1250 capped 25%; §1031 defers.
Gates. Participation counts only from the contemporaneous log (§1.469-5T(f)(4)). “Defensible” requires the engineering-based cost-seg study on file (HCA, 109 T.C. 21) — at production the reclass % comes from the study, not the slider. Modeled range — the CPA signs qualification and the method.
Cost segregation studio
Smoky Ridge Cabin · $640K
evidence · locked to study| Component | Class | Basis | % of total |
|---|
Acceleration & recapture
Material participation tracker
Saguaro Casita · 2026
at riskActivity log
0 hrs loggedStructure map
Asset isolation
Each rental sits in a single-purpose LLC. A slip-and-fall claim at Smoky Ridge is contained to Smoky Ridge — it never reaches Cliffside, the duplex, or the family's personal assets.
Holding tier
Beacon Harbor Holdings owns the property LLCs; the family trust owns the holding company. Equity and protection sit above the operating risk, not beside it.
Be your own bank
Anchor Management lends acquisition and renovation capital between the entities — each loan priced at arm's length and papered, so capital circulates inside the structure, defensibly.
Intercompany ledger
| Flow | Instrument | Amount | Rate / basis | Both sides | Lifecycle |
|---|
Document vault
Entity & ownership
Tax & substantiation
Audit-defense file
STR qualification
Structure & substance
Tax planning calendar
Acquisition analyzer
Cash flow breakdown
annualThe tax angle
Hold-period projection
Why this verdict
Show the math · statute & gates
PI = L·(r/12) / (1 − (1+r/12)^−(12·n)) where L = loan, r = rate, n = term. Annual debt service = 12·PI.
Operations. NOI = gross − (mgmt% + opex%)·gross − (property tax + insurance)
Net cash flow = NOI − debt service · Cap = NOI / price · DSCR = NOI / debt · CoC = (CF + tax saved) / cash in
The tax angle. Year-one deduction = price × cost-seg% × 100% bonus — §168(k) for property acquired and placed in service after the CFG date, reclassified per an engineering-based study (the evidence object). It offsets active income only through the §469 gate: average stay ≤ 7 days (Reg. §1.469-1T(e)(3)(ii)(A)) and material participation (§1.469-5T) — both computed from facts, both routed to the CPA. Recapture at sale: §1245 ordinary on personal property; §1250 capped at 25% on building.
Gate. This is an underwriting aid, not credit or tax advice — every determination above is the professional's call.