Interesting article on Asset/Liability Protection - Posted by Jacques

Posted by SpyBoy on September 02, 2005 at 16:48:53:

Greetings,

In response to Rainbow’s post; while I do not dispute that the IRS page referred to does state that Common Law Trusts “no longer exist”, I do dispute that the statement is in fact completely true.

I emphatically state that common law trusts presently do exist, and also that such trusts can be used as described in my previous post.

This statement is based on my 7 years of legal research and study related to the IRS and taxation in the United States, and on 3 years of legal research and study related to trusts (in general) and common law trusts (specifically).

Rainbows reference carries with it an assumption that because the IRS says it, it must be true. Making such an assumption without verifying its accuracy positions oneself to be a pawn, and a subject to liabilities that may in fact not exist. This is a rather naive view of government and power structures generally, and is contrary to our fundamental structure of government, that of “We The People” being the controllers of the government, and its revenue collection and enforcement agencies.

For the record, the IRS has been proven to have, at various times:

a) provided false and misleadiong information;

b) committed “fraud upon the court”;

c) had a policy (unwritten) of routinely violating rights of due process of law;

d) had a policy (unwritten) of violating their own procedural rules and regulations;

e) have a system of records containg personal information on every man, woman and child in America, AND, that such records contained in such database routinely contains false, misleading and patantly errouneous information. Such information is considered to be, by the IRS and the courts, “presumptively correct”.

e) of manipulating and fraudently altering the information on such database.

Each one is to make up their own mind, but for my money, based on what I have seen and heard, the fact alone that the IRS (or any government related entity for that matter) says something does not make it true. It may be or it may not be, or it may be partially, but that needs to be determined on the merits.

Remember, George Bush said there were weapons of mass destruction in Iraq. Some believed, some did not. The relevant qustion though is; was it true?

Interesting article on Asset/Liability Protection - Posted by Jacques

Posted by Jacques on September 27, 2004 at 03:55:20:

I found this article at investinginland.com. His reasoning seems to make a lot of sense.

So, does an LLC or Trust really protect investors? In what situations will it, and won’t it?

Below is part of the text of the article from that website.


Liability Protection.
Incorporating your business or transferring your real estate assets into a corporation or LLC makes no sense legally and offers you virtually no protection against lawsuits, creditors, or legal liability. This is just another of the many myths some real estate authors and gurus promote to sell courses and books on the subject. People who put their real estate into corporations or LLCs (“limited liability companies”) actually are doing themselves more legal harm than good, in fact, they are making it easier for creditors to attach their assets in the event of a lawsuit. They are also wasting a whole lot of money.

I recently received an advertisement from a well-known real estate guru and author the other day that claimed I could “shelter my real estate from liability and creditors by using a land trust, an LLC, or a Delaware or Nevada corporation.” Of course this person was selling not one but THREE $250 courses on the subject! This is also a common question I get from visitors to this website and readers of my Investing in Land Home Study Course which is usually phrased like “I’m about to buy some land and how should I take title, in my own name or should I form a corporation to hold it?”

I’ve been a lawyer for almost twenty years now and while I primarily practice real estate law, I started my career as a litigator (many lawyers do) and I’ve sued plenty of defendants on behalf of my clients over the years. I still do. So I know what I’m talking about when it comes to not only getting judgments but collecting the money owed (common called “executing”) under them.

The simple truth of the matter is that legal liability attaches not just to the legal owner of an asset but pretty much everyone who has a “nexus” or relationship to that asset or the event which gave rise to the liability. You simply cannot avoid legal liability by changing the way you legally own an asset. The only way to avoid legal liability and the financial consequences of being negligent or committing a tortious act is by not being negligent or reckless in the first place.

The reason behind this statement is also very simple. While many court cases and statutes have concluded that corporations, partnerships, LLCs, and other types of business entities are legal “persons” under law, common sense tells you that they aren’t really people. While corporations do have First Amendment rights exactly like every other American citizen, corporations are just legal creations that exist only on paper. A corporation cannot do anything from pay taxes or build a factory that the owners, directors, officers, shareholders, and employees of that corporation do not do for it. While Microsoft or Joe Smith Ice Cream, Inc. may both own assets, neither exists beyond paperwork filings at the local Secretary of State’s office. You cannot talk to or touch a corporation. But you can talk to, touch, and sue the owners, directors, officers, shareholders, and employees of a corporation, precisely those people that do the corporations bidding in the real world.

Again, you cannot escape legal liability by incorporating except by not being liable in the first place. Here are some examples explaining why.

Let’s assume Joe Smith owns some rental property and he’s concerned about liability so he creates Property Shelter, Inc. (“PS”) as a corporation to legally own his real estate assets. He transfers legal title to all his properties to PS. His lenders will allow the transfer, assuming they are paid a small fee to handle the paperwork. Such transfers are routine and banks are accustomed to doing such things. So far, Joe Smith has probably spent about $500-$1,000 to incorporate and arrange the transfers of title, maybe more if he hired a lawyer to do the incorporating and transfers for him.

So PS legally owns all the real estate. But who owns PS? Who are its officers and directors? Who manages the real estate PS owns? Who are the shareholders of PS, the real beneficial owners of the real estate it owns? It is likely that Joe Smith is one or all of the above. When Joe Smith incorporated PS and annually through his required corporate filings, who does he report as the officers and directors of the corporation? When new tenants need to be found for any of the properties PS owns, who finds them? Who makes repairs to PS properties? Who do the tenants call when something is broken or needs fixing? When the corporation shows a profit, who gets the cash money? If the answer to any of these questions is “Joe Smith” he’s liable in the event of a lawsuit.

Take this simple example based on the above facts. Let’s assume that Joe Smith manages the properties PS owns. He does the repairs, painting, finds tenants, and otherwise maintains the properties for PS. Maybe he even collects a salary from PS for doing so. One day a tenant is injured at the property because it is poorly maintained. Who is the tenant going to sue?

First, PS. The legal owner of the property. Property owners have a legal duty to maintain their properties in safe condition and this property owner was negligent.

Second, Joe Smith. He is the property manger. He has a legal duty to examine and expect the properties and make sure they are safe.

Third, the officers and directors of PS. They have a legal duty to make sure that PS complies with all required state laws.

Fourth, the shareholders of PS. Despite what you have read, shareholders of small closely-held corporations like PS get sued all the time. They can be sued under any number of theories, a common one being called “piercing the corporate veil” and it applies to corporations that are undercapitalized or really those just formed as anti-liability devices, in other words, they serve no real business purpose other than to shield owners from liability.

Joe Smith is getting sued under a variety of theories. And let’s face it. If he loses at just the corporate level, his properties are gone. If PS has to give up its real estate to settle a judgment, who cares if Joe Smith isn’t liable further down the chain?

This time, Joe gets smart!

Joe Smith gets nervous about liability after reading the above and gets himself a guru course on the subject and gets wises up really fast.

First, PS still owns his properties.

Second, he no longer manages his properties. He hires a management company to do it for him.

Third, he does not serve as the officer or director of PS. He hires other people to do it for him.

Is he safe, yet?

No, not even close.

If PS gets sued and loses, he still loses his properties. He then owns a corporation that has no assets. He can still be sued as a shareholder under various theories. He may have legal claims against the manager or the officers and directors, but he’s also been paying them to do their jobs too. At best here, Joe Smith loses his property and that’s all.

What if Joe Smith is very rich?

What if Joe Smith is a millionaire and wants to shelter all his other assets from liability in case something happens at his real estate rentals? Can he do it by using PS as a shield?

No, again. He still would be liable as a shareholder. In fact, the situation is even worse for him in many ways. Assume the reason for a lawsuit is that the property wasn’t maintained and a tenant was injured. This might suggest that PS was undercapitalized and could not make repairs and the very rich Joe Smith wouldn’t give PS the money it needed to operate and maintain its properties. I would find it very easy to pierce the corporate veil in this situation. Juries are often suspicious of rich people and especially rich people and corporations at the same time. Can you imagine how a jury would react when it learned that Joe Smith the Millionaire formed a corporation with no other purpose other than to shield him from liability but didn’t give the entity enough money to do routine maintenance and repairs on its own properties? Ever hear the expression “punitive damages”?

It really doesn’t matter what you do if you want to behave badly.

I’ve seen all sorts of devices over the years used to shield people from liability. They almost all fail. They can slow creditors down but determination beats them every time and I can honestly say the more roadblocks you throw at a creditor and their lawyer, the more relentless they become to get your money. It becomes a matter of pride after a while, a game where time is on the side of the creditor.

You can have a corporation owned by a foreign trust which holds its beneficial interest for an LLC formed in another state that is owned by another trust and so on forever. It really doesn’t matter. Ultimately there is a human being at the end of the chain and the whole charade is created to benefit that person.

Always remember that in the end…

Someone receives the profits and cash the corporation, LLC, or other entity receives.

Someone is responsible for managing the properties or assets.

Someone is responsible for operating the corporation.

Someone always is the actual owner of the entity.

And all these “someones” are flesh-and-blood people, not paper entities, and all are liable in the event of a lawsuit.

What about protecting yourself when your assets aren’t involved in a tort or negligence action?

Say, for example, Joe Smith has PS owning his properties, all of which are well-maintained and in perfect shape. His tenants love and adore him and the ground he walks on. But one night Joe Smith gets drunk with his friends and seriously injures a woman in a drunk driving accident. She sues him, claiming negligence and other tortious conduct.

Here the corporation or the management of its real estate is not the agent of the liability. Joe Smith caused the liability by his reckless conduct. The issue is whether Joe Smith can be sued but his real estate in the perfectly innocent corporation is safe from a judgment creditor.

Again, the answer is no. Joe Smith may not own the real estate but Joe Smith owns the corporation which owns the real estate. Those shares in PS are his assets that can be attached to satisfy a judgment against him. What if Joe Smith doesn’t own the shares in PS in his own name but transfers them to a trust? Then he can legally say he doesn’t own PS or any real estate, right? Wrong again. Creditor counsel will ask him if he holds any beneficial interest in any trust or real estate, it is a standard interrogatory question when attempting to collect on a judgment. What if Joe Smith does not retain any beneficial interest in the trust but passes the interest on to his wife and kids? Is he safe yet? No, once again. Because another standard interrogatory question is whether he retains any legal rights under any trust, such as to replace a trustee or direct a beneficial interest, or has recently relinquished or transferred such an interest.

This game can go on forever but ask yourself one question. If Joe Smith so divorces himself from his properties that he does not collect any income from them, has no stake in their future appreciation, and has absolutely no ownership interest in them at all, why does he want to own them anyway? Put another way, why own real estate when you legally preclude yourself from making any money in it, now and forever?

Who is concerned about legal liability? Not me.

There are two classes of people who buy into all these “corporations as liability shield” asset protection schemes.

The first class are people who do not know any better. This is the group that thinks millionaires shield their assets this way and they want to act like millionaires. The average person who owns three rental properties who fancies himself the next Donald Trump goes out and forms a variety of corporations and trusts, thinking that’s what rich people do. They don’t. This group of well-intentioned but misguided individuals are the people who buy the books and courses on land trusts and Nevada corporations. In real life most if not nearly all of these people don’t commit intentional torts and actually maintain their properties very well but they have been so scared into believing there is a hungry lawyer and plaintiff behind every tree waiting to pounce on their equity for no reason they spend thousands of dollars on meaningless “insurance” that only complicates their financial lives.

The other class of people who buy this asset protection nonsense are those who actually do behave recklessly and are worried about being sued one day. These are the men who hide assets from their wives (or vice versa) so in the event of divorce she won’t get the half she’s entitled to under the law. These are the slumlords who milk their properties and exploit tenants, promising repairs and improvements but rarely delivering on either. And these are the people who live shameful lives, they drive drunk, have promiscuous sex, gamble to excess, cheat on partners, and otherwise take inordinate risks with their lives and future. They know it is likely they will be sued so they plan ahead, not knowing what they do really has very little liability protection after all.

I know many very rich people. I mean VERY rich people. These are not the real estate investors and business owners who are obsessed with land trusts, Delaware corporations, LLCs, numbered foreign bank accounts, trusts in the Caymen Islands, and all the other silly asset protection measures you can buy books about. These people actually got to be rich by being financially responsible and ethically prudent. Many people would say they are boring because they go to church on Sunday, pay their taxes, don’t drink alcohol or have extramarital affairs, and treat their employees and tenants very well. There is a famous book called THE MILLIONAIRE NEXT DOOR by Thomas J. Stanley and William D. Danko that explains who the rich really are in America. They aren’t these flashy corporate pirates who take advantage of the weak and live in mansions and cheat the government and their business associates every chance they get. That’s the Hollywood myth from television shows like DYNASTY and DALLAS. The average millionaire is a typical run-of-the-mill person who owns and operates their own family business and has made some real money by living below their means, saving constantly, and working hard. Most millionaires in America made their own fortunes and did not inherit their money from Daddy. These people are rich precisely because they run honest businesses and live honorable and ethical lives, not because they are dishonest and have asset liability protection schemes in place that shield them from their corporate treachery and personal debauchery.

These devices actually make it easier to seize your money!

Not only don’t these land trusts and corporations protect your assets, they can actually make it easier for creditors to seize your assets.

First, there is the “all your eggs in one basket” problem. It is much easier for a creditor’s attorney to identify and attach your assets when they are all in one place, like owned by one corporation or trust.

Second, is that individuals have creditor protections that trusts, corporations, and LLCs do not have. For example, individuals have generous bankruptcy exemptions while corporations do not. Corporations and trusts are relatively defenseless in creditor proceedings while individuals can raise all sorts of claims.

Third, each time a corporation, trust, or some such entity is created it leaves a paper trail for creditors to follow. Each year documents need to be filed with public authorities like the local Secretary of State’s office, additional tax returns need to be prepared and sent to the IRS and state tax agencies, and otherwise many trees need to be felled to create all the paper these entities require. New bank accounts need to be opened and managed, new statements mailed and received, and more people keep records and become aware of these entities and their activities. Paper trails are easy to follow. If I learn that Joe Smith cashed a check from the “Acme Trust” in his personal checking account, it won’t take me long to find out who signed the check, where the money in the account came from, and who owns the trust and its assets.

There are many more reasons why creating these entities to own your assets makes it easier for creditors to seize them. My favorite reason is that when people fail to maintain these entities they are automatically dissolved by state action and many do not maintain them by paying the proper fees, filing the correct paperwork, completing the proper resolutions, and otherwise complying with the cumbersome requirements the law imposes on these entities. I know of many occasions where corporations that own valuable assets have been dissolved under state law only to have other creditors seize these assets merely by filing the appropriate paperwork with the Secretary of State’s office. So if Joe Smith owns Acme Corporation and allows its corporate status to lapse, all I have to do to own Acme’s assets is incorporate my own Acme Corporation!

How to REALLY avoid legal liability and lawsuits

Here’s some real advice on avoiding getting sued and losing your assets. Most are common sense but I’ll repeat them anyway.

First, don’t commit intentional torts. Do not drive drunk, beat up people for no reason, engage in vandalism, steal, or otherwise hurt people or their property. Be a responsible adult and don’t act like a college student on Spring Break. Don’t take on more debt than you can afford to cover. Pay your bills on time. Be a nice person and a model for your community.

Second, maintain your rental properties very well. Listen to your tenants. It pays to live in your own properties during a vacancy for a few days and learn what tenants do while living there. The major tenant concerns are repairs not being made and security issues. Address them both in advance. Most tenant based lawsuits center around very small problems that are allowed to fester into major issues, such as a broken lock on an alleyway door or a buzzer that doesn’t work that leads to a rape or other act of violence. Your tenants are your eyes and ears for your rental properties. Just don’t treat them as walking wallets that make your mortgage payments for you. Most just want a clean and safe place to live and will help you if you just ask.

Third, always maintain adequate insurance on your properties and your assets. Liability insurance can sometimes get expensive but you can get deals by shopping around and getting umbrella policies. In addition, there is much you can do to lower your premiums and insurance companies are willing to help. They don’t want to pay out awards any more than you do.

Fourth, do not maintain lots of equity in your properties. Why give a creditor’s attorney a nice fat target to shoot at? It makes no sense to have “dead equity” in properties you own from a financial planning standpoint anyway. You lower your return-on-equity by having lots of equity, you tie up valuable capital in a stale asset you already own, and invite lawsuits by flaunting your equity. Either refinance it out, create a note against it and sell it to an investor, or better still sell your property quickly and pyramid your equity elsewhere.

Fifth, do not flaunt your wealth. I like nice things too but when I deal with my tenants I wear jeans and drive my pickup truck to my rentals. If you collect your rents in a suit and tie and drive over to your building to discuss your tenant’s rent delinquency in your brand new Lexus, you are inviting trouble. Try to keep a low profile. One of the richest men in the county I live in (he owns nearly sixty rental properties in this one county alone) is only seen in public in a suit and tie once a week, and that’s on Sunday when he’s at church. Otherwise, he’s in overalls and work boots and looks like the country farmer he really is at heart.

Most importantly, be an ethical and honest person. Don’t give people reasons to sue you. Give people a dollar’s value for a dollar paid. Don’t badmouth people behind their back. Most lawsuits aren’t really about money but are about “principle” or settling scores. Sure there are greedy lawyers in this world with hungry plaintiffs who treat the courts like a lottery and an instant way to wealth. But bad lawsuits get dismissed when there are no facts underlying them and most bad ones do not get very far. You don’t hear how many lawsuits are dismissed in the press but most never make it past the preliminary stages, costing defendants little or nothing to defend against them.

You don’t need to worry about asset protection strategies and lawsuits if you give no person a reason to sue you.

A different view - Posted by FBN

Posted by FBN on December 29, 2004 at 09:01:04:

I would recommend you visit www.assetprotectioncorp.com and www.assetprotectionbook.com for a different perspective.

article - Posted by Erik

Posted by Erik on December 01, 2004 at 02:20:32:

I am a newbie but was considering this, not because I expect to get sued, but for taxes reasons. if I make 50g off a job and 50g off rent that means I am taxed 35g’s. But if the property is in a corporation which uses all it’s cash to expand, then i don’t have to pay taxes to re-invest the money, saving 17.5 thousand dollars a year.

Also I was told the point of a corp being asset protection is that you could secretly have transfered the assets of one corp to another, so if corp 1 is sued, no-one can collect because corp 2 has right to claim them first.

Asset/Liability Protection - Posted by RayS

Posted by RayS on October 06, 2004 at 22:19:20:

I’m not an Assett protection Guru, but…

Not just bad landlords get sued, good ones do also. It’s not a level playing field when your normal customer can play high stakes poker with you, when you have every thing to lose and they have nothing to lose. Not a fair playing field. In my opinion it’s common sense to put as many obstacles up as reasonably possible. Maybe Jacques can clarify this for me and give me an opinion of LLC’s. Whats the track record of piercing these type of entites, is this commonly done. It’s my understanding the rules are much more relaxed than with corporations. It seems to me that every attorney has to decide if its worth their time to pursue. They have to decide how much effort and expense they are willing to undertake. Obstacles like LLC’s have surely reduced nuisance lawsuits. For example if a tenants dog bites a person on my property some attorney and their client would probably think thats my fault. Now Imagine an Out of State LLC owned the property, since the client has no money, how much is the Contingency attorney going to spend going after this client, what if it were a weak case. What if there was conveinently a large first lien on the property.

Jaques your final statement assumes that people only sue you when they are damaged. But I was sued and spent Thousands defending myself just to have the Jury find in my favor. Twenty years of hard work could have went up in smoke(thousands of dollars did). The jury could have went the other way. I still lost in stress, time and money.
When you say that you have nothing to worry about, it sound as if you have never been sued or you don’t have any assets.

Asset protection gurus, please comment. nt. - Posted by randyOH

Posted by randyOH on September 28, 2004 at 11:22:37:

nt

Re: Asset/Liability Protection - Posted by SpyBoy

Posted by SpyBoy on October 20, 2004 at 16:55:17:

Greetings,

I have an extensive understanding of the concepts and the mechanics of “asset protection”,both on-shore and off-shore, and I keep up mon the latest legal developments. I do not have much time at the moment to address this,as it can be an extremely complex subject, but will offer a few comments.

First, this persons comments are valid, but I believe that he does not have a complete understanding of what asset protection really is and what it is designed to do. The comments are offered from a particular perception. Perception is often more important than reality, but it is not reality.

Second, entity structuring will not (not always, but sometimes) be a protection in instances of fraud and/or negligence, as is proper. Asset protection is designed to protect against frivilous actions and the extremely litigeous nature of our legal system. ( also for “legal tax avoidance”, probate avoidance, and passing on the estate)

Third, consider that a primary concept of asset protection is to make it more difficult and expensive to prevail in an action and to collect on a judgement. That in itself will deter most of the phoneys.

If, for example, an attorney has to sue a trustee of a land trust, and prevail, and then sue an llc, and prevail, and than go to, for example, Panama, and sue an International Business Company, using a Panamanian attorney, and prevail there, and get valid judgements on each, and there must be available assets to collect on, which may or may not be the case, well, that attorney might just tell the potential client that it is just not feasible to persue it. If the client was expecting the attorney to take the case on a “contingency basis”, he would be disappointed. If he insisted on moving forward, the attorney would ask for something like a $50.000 retainer, and it would cost more than that in the long run.

Fourth, a primary concept of asset protection is privacy. The comments he offers indicates that he does not understand the stradigies available to maintain privacy. For instance, there are “nominee” officers and directors, although one must use caution in this, as there are liabilities. Whatever the particular method, the fact is that it is possible to be beneficiary of a land trust, a member of an llc, a shareholder (even sole) of a corporation, and not show in the public records. Now, that does not mean that a determined litigant and/or attorney could not find out that information.

The point is that asset protection through enitiy structuring does have an effect, and can be a useful tool for some. To consider are the knowledge and experience of the person/company doing the actual advising, consulting, and support services, the value for cost ration (is what I’m getting worth what I’m paying), and ones actual need.

For those interested I suggest finding out the fundamentals for yourself. Go to Google and search around. I would also say that while it may seem complicated, anyone can establish a corporate entity. Its not rocket science.
Well, thats all folks. I hope this is useful.
SoyBoy

Re: Asset/Liability Protection - Posted by Paul E. Welborn,Jr.

Posted by Paul E. Welborn,Jr. on February 21, 2005 at 07:32:21:

But what about the chicken and egg question of, Friends Romans and countrymen shall I place my property in an LLC and allow the trust to make the liens or mortgages or the trust to hold the property and allow the LLC to do the liens or mortgages. Pro’s and cons of each please !

Re: Asset/Liability Protection - Posted by SpyBoy

Posted by SpyBoy on February 22, 2005 at 23:23:58:

Here’s one way;

Wyoming LLC (private, no state income tax and no business license requirement).

Two seperate common law trusts as members of LLC.

Manager of LLC is a foreign corporation (an International Business Corp.).

Each individual investment property is held in a “Illinois type land trust”, with the LLC as the beneificiary (there may be others according to circumstances).

You (the individual investor) can be the trustee of the land trust, if desired, or could appoint another. You could also be the manager of the LLC, instead of the foreign corp.

In a situation where one brought a frivilous lawsuit against the property owner, the Land Trust, they would have to sue the trust. The only asset the trust holds is the property, which can have a prior and priority lien against it.

If one insisted on going forward, further than the land trust, they would have to sue two common law trusts, which only a small percentage of all lawyers actually understand, then would have to sue an international corporation, possibly in a foreign country.

While not saying it could’nt happen, but it most likely would not happen.

Keep in mind that this structure, or any like it, DO NOT protect against fradulent, corrupt, deceptive and/or dis-honest busine practices or personal conduct.

SpyBoy

IRS on “Common Law Trusts” - Posted by Rainbow

Posted by Rainbow on September 01, 2005 at 22:02:31:

This is from the IRS Web site. http://www.irs.gov/businesses/small/article/0,,id=106553,00.html

Common Law Trust

Contrary to the claims of promoters, “common law trusts” no longer exist since all states now have statutes relating to the creation and operation of trusts.