New Land Enterprises
Founded in 1993, New Land Enterprises is a Milwaukee-based real estate development, acquisition, and management group of companies. Since its inception, New Land has celebrated many firsts. It has identified up-and-coming neighborhoods and was the first to develop market-rate new construction multi-family in the Third Ward, Brewer’s Hill, Farwell Ave., and Riverwest. New Land has also won 9 of 11 RFPs in which it’s competed.
New Land was the first to standardize the use of the latest building amenities, from granite countertops and stainless-steel appliances in the mid-2000s to modern amenities like radiant heated floors. It has pioneered innovative building designs and techniques like the use of light gauge steel in multi-family mid-rises, Milwaukee’s first micro-units, and the use of mass timber.
Today, the company owns and manages 1,636 apartments and 200,000 SF of commercial space. It has developed 27 projects, adding over 2,000 units to downtown Milwaukee.
Wiechmann Enterprises
Founded in 1964, Wiechmann Enterprises is a Wisconsin-based property management, brokerage, and real estate development company that owns and operates over 3,000 apartments and over 100,000 square feet of commercial real estate in Wisconsin and Florida. Wiechmann Enterprises is a longtime partner and collaborator with New Land, leveraging their combined resources to the maximum benefit for each project.
This is an opportunity for investors to partially recapitalize an existing limited partner. New investors from the RealtyMogul platform have an opportunity to invest in an iconic multifamily project mid-construction at the original cost basis set forth at construction commencement in September 2020. The investors will start accruing the preferred return starting January 1st, 2022 when the project's construction is approximately 60% complete. The Property's mass timber construction offers incomparable aesthetics, setting the Project apart from every other multifamily property in the market, and is set to open in June 2022.
| # of Units | SF | Average Rent | Average $/SF | |
| 1 BR 1 BA (Junior) | 16 | 573 | $1,715 | $2.99 |
| 1 BR 1BA | 141 | 821 | $2,334 | $2.77 |
| 2 BR 2 BA | 33 | 1,288 | $3,425 | $2.89 |
| 2 BR + | 32 | 1,362 | $5,525 | $3.77 |
| 3 BR | 33 | 1,747 | $6,850 | $3.91 |
| Penthouse | 4 | 2,153 | $9,233 | $4.26 |
| Total/Averages | 259 | 1,071 | $3,511 | $3.20 |
Lease Comparables
| 7Seventy7 | Park Lafayette Tower | Domus | Comp Averages | Ascent | |
| Address | 777 E Van Buren St. | 1918 E Lafayette Pl | 441 E Erie St. | ||
| CoStar Class | 5 Star Hi-Rise - Class A | 3 Star Hi-Rise Apartments Condo - Class B | 4 Star Mid-Rise Apartments Condo - Class A | 5 Star Hi-Rise - Class A | |
| Year Built | 2018 | 2011 | 2017 | 2022 | |
| Units | 310 | 271 | 132 | 238 | 259 |
| # of Studios | 32 | N/A | N/A | 32 | $16 |
| Studio Rent | $1,672 | N/A | N/A | $1,672 | $1,715 |
| Studio SF | 550 | N/A | N/A | $550 | $573 |
| Average Studio $/SF | $3.04 | N/A | N/A | $3.04 | $2.99 |
| # of 1x1 | 176 | 115 | 94 | 385 | 141 |
| 1x1 Rent | $2,018 | $1,795 | $2,010 | $1,941 | $2,334 |
| 1x1 SF | 720 | 825 | 710 | 752 | 821 |
| Average 1 BR $/SF | $2.80 | $2.18 | $2.83 | $2.60 | $2.84 |
| # of 2x2 | 82 | 146 | 36 | 88 | 33 |
| 2x2 Rent | $3,259 | $2,662 | $3,508 | $3,143 | $3,425 |
| 2x2 SF | 1,066 | 1,248 | 1,377 | 1,230 | 1,288 |
| Average 2 BR $/SF | $3.06 | $2.13 | $2.55 | $2.58 | $2.66 |
| # of 3x2 | 20 | 19 | 2 | 14 | 33 |
| 2x2 Rent | $6,646 | $3,716 | $5,750 | $5,371 | $6,850 |
| 2x2 SF | 1,699 | 1,718 | 1,785 | 1,734 | 1,747 |
| Average 3 BR $/SF | $3.91 | $2.16 | $3.22 | $3.10 | $3.92 |
| GBA - SF | 925,600 | 325,000 | 120,000 | 456,867 | 493,000 |
| Distance to Subject | .19 mile | 1.22 mile | .98 mi | ||
| Notes | Closest Comp | Reasonable Comp because of such limited competition but is older with inferior finishes amenities and less desirable location | Close Comp but smaller and fewer amenities | The best comp is 7Seventy7. Location, size, class, amenities level, and age. |
Construction Comparables
| Two Twelve Clayton | Ballpark Village | @580 | 360 Market Square | Total/Averages | Ascent | |
| Market | St. Louis, MO | St. Louis, MO | Cincinnati, OH | Indianapolis, IN | Milwaukee, WI | |
| Year Built | 2017 | 2020 | 2016 | 2018 | 2018 | 2022 |
| Asking Rent | $2,498 | $3,390 | $2,395 | $2,422 | $2,676 | $3,511 |
| Units | 250 | 297 | 179 | 292 | 255 | 259 |
| Construction Cost | $100,000,000 | $102,000,000 | $75,000,000 | $90,000,000 | $91,750,000 | $125,968,584 |
| Cost/Unit | $400,000 | $343,434 | $418,994 | $308,219 | $367,662 | $486,365 |
Sales Comparables
| 1079 N High St | 1717 Ridge Ave | 2190 E 11th Ave | 3000 Pearl Pky | The Pullman | Total/Averages | Ascent | |
| Market | Columbus, OH | Evanston, IL | Denver, CO | Boulder, CO | Denver, CO | Milwaukee, WI | |
| Year Built | 2020 | 2013 | 2015 | 2022 | 2020 | 2018 | 2027 |
| Asking Rent | $2,117 | $3,561 | $2,764 | $2,989 | $6,553 | $2,858 | $3,511 |
| Units | 113 | 175 | 156 | 244 | 168 | 171 | 259 |
| Sale Price | $54,595,000 | $71,000,000 | $90,530,000 | $151,250,000 | $174,250,000 | $108,325,000 | $175,647,023 |
| Cost/Unit | $483,142 | $405,714 | $580,321 | $619,877 | $1,037,202 | $625,251 | $678,174 |
Total Capitalization
| Sources of Funds | $ Amount |
| Developer's Contributed Land Equity(1) | $2,045,000 |
| Additional Investor Land Equity(1) | $4,205,000 |
| Wood Innovation Grant (USDA) | $350,000 |
| Sponsor (and affiliate of Sponsor) Cash Equity(5) | $19,300,000 |
| Investor Cash Equity | $7,113,584 |
| LP Investor Equity(2) | $5,305,000 |
| Total Equity | $38,318,584 |
| Mezzanine Debt | $25,000,000 |
| Construction Loan | $62,650,000 |
| Total Sources of Funds | $125,968,584 |
| Uses of Funds | $ Amount |
| Land | $6,250,000 |
| Hard Costs(3) | $93,783,746 |
| Soft Costs(3) | $17,520,531 |
| Contingency | $4,609,317 |
| Developer's fee | $3,500,000 |
| Closing Costs(2)(6) | $304,990 |
| Total Uses of Funds(4) | $125,968,584 |
(1) The Sponsor acquired the land in 2008 for $2,045,000. Since then, the Sponsor has paid all expenses associated with holding the land and has successfully re-zoned the parcel and received permit approvals to develop the 259-unit multifamily Project. The passage of time and rezoning+permitting implies an increased land valuation since the date of original acquisition (e.g., a land mark-up of $4,205,000).
(2) Includes costs associated with the closing for Investors sourced on the RM Platform.
(3) The Sponsor is anticipating increased Project costs of about $1.75M. The Sponsor is arranging a Bridge Loan at 8% interest for these costs which will be paid back out of refinancing proceeds.
(4) Total Project Cost exceeds sources and uses because a portion of the interest due on the Mezz loan is deferred.
(5) The Sponsor’s equity contribution may consist of friends and family equity and equity from funds controlled by the Sponsor.
(6) RM Technologies, LLC, an affiliate of RealtyMogul, operates the RealtyMogul Platform. RM Technologies, LLC charges a fixed, non-percentage-based fee for real estate companies and their sponsors to use the Platform and for Platform-related services. Please see the Fees and Disclaimers sections below for additional information concerning fees paid to RM Technologies, LLC.
The expected terms of the debt financing are as follows:
Mezzanine Loan Terms
- Lender: HINES
- Term: 36 months + two 1-year extensions
- Loan-To-Value: 20.0%
- Estimated Proceeds: $25,000,000
- Interest Type: Fixed
- Annual Interest Rate: 8.50%
- Interest-Only Period: Full-term
- Amortization: Carried interest equal to 3.5% due at Mezz loan payoff
- Extension Requirements: Aggregate Debt Yield 6.5%
- Recourse: Completion guaranty
- Security: Underlying asset
- Modeled Refinance: Yes
Construction Loan Terms
- Lender: Bank OZK
- Term: 36 months + two 1-year extensions
- Loan-To-Value: 50.0%
- Estimated Proceeds: $62,650,000
- Interest Type: Fixed
- Annual Interest Rate: 4.75%
- Interest-Only Period: Full-term
- Amortization: Upon loan extension
- Prepayment Terms: Minimum of $3.85M interest to have been paid
- Extension Requirements: DSC 1.5; Debt Yield 9.75%
- Recourse: Completion guaranty
- Security: Underlying asset
- Refinance Information: Projected 10 year agency refi
Modeled Refinance
- Term: 10 years
- Estimated Proceeds: $111,000,000
- Interest Type: Fixed
- Annual Interest Rate: 3.95%
- Interest-Only Period: 36 months
- Amortization: 30 years
There can be no assurance that the Sponsor will secure debt on the rates and terms noted above, or at all. All of the Sponsor’s estimated rates and terms of the debt financing are subject to lender approval, including but not limited to possible increases in capital reserve requirements for funds to be held in a lender-controlled capital reserve account.
A substantial portion of the total acquisition for the Property will be paid with borrowed funds. The use of borrowed money to acquire real estate is referred to as leveraging. Leveraging increases the risk of loss. If the Sponsor were unable to pay the payments on the borrowed funds (called a "default"), the lender might foreclose, and the Sponsor could lose its investment in its property.
The Sponsor intends to make distributions from RM Ascent Investor LLC as follows:
- 8% cash-on-cash priority preferred return (simple, annual accruing not compounding);
- thereafter, a 75% to A-members (inclusive of new investors sourced on RM's Platform) / 25% to B-members with clawback.
The Sponsor intends to make distributions to investors after the payment of the company's liabilities (loan payments, operating expenses, and other fees as more specifically set forth in the LLC agreements, in addition to any member loans or returns due on member loan).
Distributions are expected to start in January 2025 and are projected to continue on a quarterly basis thereafter. Distributions are at the discretion of the Sponsor, who may decide to delay distributions for any reason, including maintenance or capital reserves.
The Sponsor will receive a promoted/carried interest as indicated above, and a portion of this promoted/carried interest may be received by RM Admin, LLC.
| Cash Flow Summary | |||||
| Year 1 | Year 2 | Year 3 | Year 4 | ||
| Effective Gross Revenue | $6,740,601 | $12,100,536 | $11,992,861 | $12,292,682 | |
| Total Operating Expenses | $3,595,404 | $3,951,407 | $4,035,351 | $4,037,272 | |
| Net Operating Income | $3,145,197 | $8,149,129 | $7,957,510 | $8,255,410 | |
| Project-Level Cash Flows(1)(2)(4) | |||||
| Year 0 | Year 1 | Year 2 | Year 3 | Year 4 | |
| Net Cash Flow | ($38,020,000) | $0 | $17,495,240 | $3,264,749 | $50,637,593 |
| Investor-Level Cash Flows(3) | |||||
| Year 0 | Year 1 | Year 2 | Year 3 | Year 4 | |
| Net Cash Flow | ($5,305,000) | $0 | $2,244,716 | $375,731 | $6,597,521 |
| Investor-Level Cash Flows - Hypothetical $50,000 Investment(3) | |||||
| Year 0 | Year 1 | Year 2 | Year 3 | Year 4 | |
| Net Cash Flow | ($50,000) | $0 | $21,157 | $3,541 | $62,182 |
(1) Includes D-Unit equivalent of $50,186 for IRR calculation purposes.
(2) Applies to RM Ascent Investor LLC A-members only - IRR calculation includes the full $5,305,000 invested into RM Ascent Investor LLC which also covers $304,990 of Offering costs and interest.
(3) Returns are net of all fees. Such Fees include fees paid to RM Admin, an affiliate of RealtyMogul, who charges an annual fixed administrative fee for providing certain ongoing administrative services to the Sponsor. Please see the Fees and Disclaimers sections and Disclaimers sections below for additional information concerning fees paid to RM Admin.
(4) These amounts are expected to change based on repayment of the Bridge Loan. There can be no guarantee that these amounts will be achieved.
The hold period for new investors from RM's Platform will commence 16 months into the Project's original construction. While the Project cash flows are reflective of a 5-year hold period, the remaining hold period for RM investors is 4-years.
RM Technologies, LLC and its affiliates does not provide any assurance of returns. The content on this Page, including the Sponsor’s pro forma projections, was provided by the Sponsor or an affiliate thereof. Although RM Technologies, LLC believes the Sponsor reliably produced this content, RM Technologies, LLC makes no representations or warranties as to the accuracy of such information and accepts no liability therefor. The assumptions and projections included in the content on this Page, including the Sponsor’s pro forma projections, are not reflective of the position of RM Technologies, LLC or any other person or entity other than the Sponsor or its affiliates. There can be no assurances that all or any of the Sponsor’s assumptions will be true, that actual performance will bear any relation to these hypothetical illustrations, or that the Sponsor’s investment objectives will be achieved. For additional information concerning the Sponsor’s assumptions and projections, and the significant risks involved in investing in real estate, please see the Disclaimers section below.
Certain fees and compensation will be paid over the life of the transaction; please refer to the Sponsor's materials for details. The following fees and compensation will be paid(1)(2)(3)(4)(5)(6)(7)(8)(9):
| One-Time Fees: | |||
| Type of Fee | Amount of Fee | Received By | Paid From |
| Developer's Fee(7) | $3,500,000 | Bookends North Sponsor LLC | Deal Capitalization |
| Owner/Site Rep Fee | $400,000 | New Land Property Management LLP | Deal Capitalization |
| Lease Up Fee | $1,250 per unit leased until 208 units are leased. | New Land Property Management LLP | Deal Capitalization and Cash Flow |
| Disposition Fee | 25 basis points of the sale price | New Land Property Management LLP | Sale Proceeds |
| Grant Procurement Fee | $25,000 | New Land Property Management LLP | Deal Capitalization |
| Recurring Fees: | |||
| Type of Fee | Amount of Fee | Received By | Paid From |
| Property Management Fee | 2.75% of revenues collected | New Land Property Management LLP | Cash Flow |
| Asset Management Fee | 0.75% of revenues collected | New Land Property Management LLP | Cash Flow |
| Administrative Services Fee | 1.0% of Equity(1) | RM Admin(3) | Distributable Cash |
| Leasing Commissions(5) | 4.0% of Retail Commissions | New Land Property Management LLP | Cash Flow |
| Refinancing Fee | 15 basis points of refinancing | New Land Property Management LLP | Refinance Proceeds |
| Property Management Construction Fee(8) | 5.0% of construction costs beginning 60 days after occupancy permit | New Land Property Management LLP | Cash Flow |
| Guaranty Fee(6) | 2.0% | Manager or Affiliate | Cash Flow |
| Other(9) | Varies | New Land Property Management LLP | Cash Flow |
(1) Only applies to equity raised through the RealtyMogul Platform
(2) Fees may be deferred to reduce impact to investor distributions.
(3) RM Technologies, LLC, an affiliate of RealtyMogul, operates the RealtyMogul Platform. RM Technologies, LLC charges a fixed, non-percentage-based fee for real estate companies and their sponsors to use the RM Technologies, LLC’s proprietary Platform and receive Platform-related services. An estimate of this fee is included in the Closing Costs above and is intended to be capitalized into the transaction at the discretion of the Sponsor. The Platform fees received by RM Technologies, LLC are disclosed in the relevant operating agreement(s). RM Technologies LLC’s receipt of Platform fees creates a conflict of interest between RealtyMogul and its affiliates, and investors or prospective investors.
(4) RM Admin, an affiliate of RealtyMogul, charges an annual fixed administrative fee for providing certain ongoing administrative services to the Sponsor. RM Admin’s administrative services and fees are disclosed in the relevant operating agreement(s). RM Admin’s receipt of administrative fees creates a conflict of interest between RealtyMogul and its affiliates, and investors or prospective investors.
(5) Equal to 4.00% of the value of the net rents on the retail space over the initial term of any lease entered into during the term of the Property Management Agreement and 2.00% of the net rents over the initial term of any renewal or renegotiation
(6) Manager or an Affiliate of Manager may earn 2.00% of any recourse Loan to the Project that is personally guaranteed by the Manager or any Affiliate of the Manager who is a guarantor. The Guaranty Fee is not earned for bad acts carveouts or completion guarantees.
(7) A “Development Fee” of $3,500,000 payable monthly in proportion to the percentage of completion of construction of the Project, plus reimbursement for all development costs incurred by the Developer on behalf of the project, but expressly excluding Developer’s internal costs. Notwithstanding the foregoing, Developer is forgoing $50,186 of the Development Fee in exchange for the issuance of 1.32 D-Units which constitutes an ownership interest in the Company and is subject to certain claw back provisions. The final payment of the Development Fee shall be paid to Developer no later than thirty (30) days after substantial completion of the Project, as evidenced by a certificate of occupancy being issued for the Project. For purposes of this Section, “development costs” shall mean all out-of-pocket costs incurred in connection with the Project that are not costs associated with operating the Developer’s business entity or the Developer’s general overhead.
(8) Beginning 60 days after the Project receives its occupancy permit, for any construction projects taking place at the Property, (including but not limited to building renovations, restorations, and tenant improvements) that exceed $50,000, a construction representative fee of five percent (5%) of the total amount of the construction project, for assistance with the construction at the Property, payable as a percent of completion of such project on a monthly basis.
(9) Please see Offering Documents for more details. Sponsor provides for common incidental and maintenance of the property.
RM Securities, LLC, its registered representatives, affiliates, associated persons, and personnel of its affiliates who may also be associated with it, including our associated persons and personnel of our affiliates who are also be associated with RM Securities, LLC (it (“RM Securities,” “we,” “our,” or “us”) will receive fees, expense reimbursements, and other compensation (“Fees”) from the issuer of this investment offering, its sponsor, or an affiliate thereof (“Sponsor”), or otherwise in connection with Sponsor’s offering. The Fees paid to us are in addition to other fees you will pay to Sponsor or in connection with Sponsor’s investment offering. You will pay Fees to Sponsor, either directly or indirectly as an investor in the Sponsor’s offering. Sponsor will use the Fees you pay, as well as funds you invest in the relevant offering, to compensate us. The Fees paid to us will directly or indirectly be borne by you as the investor (typically, but not always, in the form of an expense of the Sponsor’s offering in which you invest) because such Fees will reduce the proceeds available for distribution to you and reduce the amount you earn over time.
For more information on the Fees paid to us, or any other Fees you will pay in connection with Sponsor’s offering, please carefully review the Sponsor’s Investment Documents. Please also carefully review RM Securities’ Form CRS, Regulation Best Interest Disclosures, and Limited Brokerage Services Agreement.
No Approval, Opinion or Representation, or Warranty by RM Securities, LLCSponsor has provided, approved, and is solely responsible in all aspects for the information on this webpage (“Page”), including Sponsor’s offering documentation, which may include without limitation the Private Placement Memorandum, Operating or Limited Partnership Agreement, Subscription Agreement, the Project Summary and all exhibits and other documents attached thereto or referenced therein (collectively, the “Investment Documents”). The Investment Documents linked on this page have been prepared and posted by Sponsor, and not by RM Securities. We did not assist in preparing, do not adopt or endorse, and we are not otherwise responsible for, the Sponsor’s Investment Documents. We make no representations or warranties as to the accuracy of information on this Page or in the Sponsor’s Investment Documents and we accept no liability therefor. No part of the information on this Page or in the Sponsor’s Investment Documents is intended to be binding on us.
Sponsor’s Information Qualified by Investment DocumentsThe information on this Page is qualified in its entirety by reference to the more complete information about the offering contained in the Sponsor’s Investment Documents. The information on this Page is not complete and subject to change at the Sponsor’s discretion at any time up to the closing date. The Sponsor’s Investment Documents and supplements thereto contain important information about the Sponsor’s offering including relevant investment objectives, the business plan, risks, charges, expenses, and other information, which you should consider carefully before investing. The information on this Page should not be used as a basis for an investor’s decision to invest.
Risk of InvestmentThis investment is speculative, highly illiquid, and involves substantial risk. There can be no assurances that all or any of Sponsor’s assumptions, expectations, estimates, goals, hypothetical illustrations, or other aspects of Sponsor’s business plans (“Assumptions”) will be true or that actual performance will bear any relation to Sponsor’s Assumptions, and no guarantee or representation is made that Sponsor’s Assumptions will be achieved. If Sponsor does not achieve its Assumptions, your investment could be materially and adversely affected. A loss of part or all of the principal value of your investment may occur. You should not invest unless you can readily bear the consequences of such loss. Sponsor’s Assumptions should not be relied upon as the primary basis for your decision to invest.
No Reliance on Forward-Looking Statements; Sponsor AssumptionsSponsor is solely responsible for statements made concerning forward-looking statements and Assumptions, which apply only as of the date made, are preliminary and subject to change, and are expressly qualified in their entirety by the disclosures and cautionary statements included in Sponsor’s Investment Documents, which you should carefully review. Neither RM Securities nor Sponsor are obligated to update or revise such forward-looking statements or Assumptions to reflect events or circumstances that arise after the date made or to reflect the occurrence of unanticipated events. Sponsor’s forward-looking statements and Assumptions are hypothetical, not based on actual investment achievements or events, and are presented solely for purposes of providing insight into the Sponsor’s investment objectives, detailing Sponsor’s anticipated risk and reward characteristics, and establishing a benchmark for future evaluation of actual results; therefore, they are not a predictor, projection, or guarantee of future results. You should not rely on Sponsor’s forward-looking statements as a basis to invest.
Importantly, we do not adopt, endorse, or provide any assurance of returns or as to the accuracy or reasonableness of Sponsor’s Assumptions or forward-looking statements.
No Reliance on Past PerformanceAny description of past performance is not a reliable indicator of future performance and should not be relied upon as the primary basis to invest.
Sponsor’s Use of DebtA substantial portion of the total cost of the real estate asset acquired by the Sponsor with investor funds (“Property”) will be paid with borrowed funds, i.e., debt. Sponsor’s estimated rates and terms of the debt financing are subject to lender approval, and there is no assurance that the Sponsor will secure debt at the rates and terms presented on this Page or in the Sponsor’s Investment Documents, or at all. The use of borrowed money to acquire real estate is referred to as leveraging, which can amplify losses and could result in lender foreclosure. In addition, if the debt includes a variable (or “floating”) interest rate, the total amount of interest paid over the term of the debt will fluctuate and can increase. As a result, Sponsor’s use of debt can result in a loss of some or all of your investment.
Sponsor’s Offering is Not RegisteredSponsor’s securities offering will not be registered under the Securities Act of 1933, as amended (the “Securities Act”), in reliance upon the exemptions from registration pursuant to Rule 506(c) of Regulation D as promulgated under the Securities Act (“Private Placement”). In addition, the offering will not be registered under any state securities laws in reliance on exemptions from state registration. Such securities (your ownership interests) are subject to restrictions on transferability and resale and may not be transferred or resold except as permitted under applicable state and federal securities laws pursuant to registration or an available exemption. All Private Placements on the Platform are intended solely for “Accredited Investors,” as that term is defined in Rule 501(a) under the Securities Act.
No Investment AdviceNothing on this Page should be regarded as investment advice (either with respect to a particular security or regarding an overall investment strategy), a recommendation, an offer to sell, or a solicitation of or an offer to buy any security. Advice from a securities professional is strongly advised to understand and assess the risks associated with real estate or private placement investments. For additional information on RM Securities’ involvement in this offering, please carefully review the Sponsor’s Investment Documents, and RM Securities’ Form CRS, Regulation Best Interest Disclosures, and Limited Brokerage Services Agreement.
1031 Exchange RiskInternal Revenue Code Section 1031 (“Section 1031”) contains complex tax concepts and certain tax consequences may vary depending on the individual circumstances of each investor. RM Securities and its affiliates make no representation or warranty of any kind with respect to the tax consequences of your investment or that the IRS will not challenge any such treatment. You should consult with and rely on your own tax advisor about the tax aspects with respect to your particular circumstances.