10C — January 22 - February 18, 2021 — Owners, Developers & Managers — M id A tlantic Real Estate Journal


O wners , D evelopers & M anagers

The Renaissance at Lincoln Parkwill feature 179 workforce housing units &Boys and Girls Club facility The NRP Group breaks ground on community- centered development in New Rochelle, NY

EW ROCHELLE, NY — In the midst of a tumultuous and challenging year, the Re - naissance at Lincoln Park, a transformational community- driven and centered devel - opment in the City of New Rochelle broke ground today. Embodying the resilient spirit of the Queen City and its cur - rent evolution, the project will create 179 units of best- in-class workforce housing, a state-of-the-art Boys & Girls Club facility and 350 parking spaces for residents, commu - nitymembers, and park-goers. The NRP Group , a ver- tically-integrated develop - er, builder, and manager of multifamily housing, leads a joint-venture development partnership between the New Rochelle-based non-profit Guion Renaissance Hous- ing Development Finance Corporation (HDFC) , and Kensworth Consulting . The Boys and Girls Club of New Rochelle and The City of New Rochelle are project partners. The total development cost of the project is $97 million and is financed by multiple fund - ing sources. The New York State Homes & Community Renewal provided significant support including $48 million of tax exempt bonds issued by its Housing Finance Agency. Red Stone Equity Partners provided tax credit equity syndication with Bank of New York Mellon as the investor and letter of credit provider. The developer also provided N the carryover holding period for the capital asset exceeds three years. The distribution in kind and subsequent disposition of a capital asset that has been held three years or less will result in taxation on the gain as a short- term capital asset instead of a long-term capital asset under Section 1061. It is prudent to note that the proposed regulations do not apply to items charac - terized as long-term capital assets under other provisions such as Section 1231 gain from the disposition of prop - erty used in a commercial or residential real estate rental. In other words, when real estate is used in a trade or business, the resulting gain

great futures. The Club serves more than 3,675 children and teens every year and the new 23,400 s/f clubhouse will allow the organization to serve more needy children and families and amplify its impact. The new facility will include a gym, basketball court, record - ing studio, demonstration kitchen, administrative of - fices, and rooms designed for work and play. New York State Homes and Community Renewal Com - missioner RuthAnne Visnaus - kas said: “With 179 affordable and energy-efficient homes, The Renaissance at Lincoln Park furthers Governor Cuo - mo’s ambitious five-year, $20 billion housing plan to bring new affordable housing to communities across the state. Our investment in this new development includes the construction of a brand new, state-of-the-art home for the Boys and Girls Club, an orga - nization that provides such an important service to the city’s youth. Together with the Governor’s Downtown Re - vitalization Initiative award, The Renaissance at Lincoln Park will enhance economic activity along the Lincoln Av - enue corridor, improve access to quality housing for families and help build a brighter and stronger future for New Ro - chelle.” “The Remington clubhouse has always been a very neigh - borhood-centric space that community members feel a tremendous sense of pride and

ownership over,” said Lutonya Russell-Humes, executive director of the Boys & Girls Club of New Rochelle. “The clubhouse is definitely due for an upgrade, and we look forward to the new, larger space that will let us bring in even more of the community and build on the generational investment of the community into this space.” “The Boys and Girls Club of New Rochelle is an essential institution to the children and families in District 3, and we are thrilled to see a new and improved clubhouse,” said Councilwoman Yadira Ramos-Herbert. “Members of District 3 are thrilled with the affordable, high-quality hous - ing that will be located right in the heart of the Lincoln Avenue Corridor. My heartfelt thanks to everyone who had a hand in making this project possible.” "I could not have asked for a better retirement gift then having one of the crown jewels of all of our projects become a reality,” said Luiz Aragon, Commissioner of Development for the City of New Rochelle. “This is such an important project for the community and by the community that will truly make a difference in creating new affordable hous - ing opportunities, more youth services and a shared value in building a better and brighter New Rochelle. Congratula - tions to The Renaissance at Lincoln Park on today’s vir - tual groundbreaking.” MAREJ

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Boys & Girls Club facility rendering

equity for the project with additional support from the Interfaith Development Cor - poration and the Westchester County Housing Infrastruc - ture Fund. “This new community de - velopment is an exciting step forward for New Rochelle, offering affordable high-qual - ity housing, coupled with the most significant new youth services facility in genera - tions,” said Noam Bramson, Mayor of New Rochelle. “I am grateful for the public-private partnership that is bringing this positive vision to life.” “By offering exceptional affordable housing and nu - merous community benefits, including space for local chil - dren to learn and grow, the Renaissance at Lincoln Park will help strengthen and sup - port the City of NewRochelle,” said Kenneth Plummer , CEO of Kensworth Consult - ing. “As a community-minded developer, I’m confident that this project will set the stan - dard for inclusive, community- attributable to the sale of the real estate will not be im - puted with ordinary income tax rates under Section 1061, even if the holding period of the real estate was for less than three years. Alterna - tively, if the partners of an API that holds real property, with a holding period of less than three years , sell their partnership interest, the recognized gain would be sub - ject to ordinary income rates under Section 1061. Conclusion The proposed regulations are general ly taxpayer- friendly and consistent with how taxpayers have been in - terpreting Section 1061 since enactment. Section 1061 introduces anti-avoidance

centered development and power the sustainable growth of cities across the nation.” “The Renaissance at Lin - coln Park is an example of the incredible power of public and private partnership,” said Reverend Michael Rouse , president of Guion Renais - sance Housing Development Finance Corporation. “By listening to the community, allowing its needs to drive the vision and scale, and ensur - ing our involvement at every level, our team has ensured that this project will be trans - formative for New Rochelle, benefiting the most vulnerable and shaping the future of our City for generations to come.” Community is at the heart of the Renaissance at Lincoln Park, which features a sleek, modern facility for the Rem - ington Clubhouse of The Boys & Girls Club of New Rochelle. The organization provides a safe space, mentoring, and quality programs that em - power local vulnerable youth to excel in school and build rules, including rules relating to the distribution of property with a holding period of three years or less and to the sale of partnership interests. The carried interest provi - sions of Section 1061 can be complicated and nuanced. Taxpayers should hire their own captain to navigate these somewhat “dangerous” rules in order to keep as much of their booty as possible. The proposed regulations discussed above were final - ized on 01/07/21 Please reach out to one of our Withum Real Estate team captains for further guidance as needed. Jeffrey A. Clayman, CPA, JD, LLM-Tax is senior manager at Withum . MAREJ

continued from page 3C Internal Revenue Code Section 1061 Proposed Regulations – Pirates of the Carried Interest

Livingston Street Capital bolsters 55+ adult portfolio withmultifamily acquisition

ELLICOTT CITY, MD — An affiliate of Livingston Street Capital has acquired Alta at Regency Crest , 150- unit 55+ adult lifestyle multi - family community in Ellicott City. This acquisition comes on the heels of three recent 55+ active adult living property ac - quisitions by Livingston affili - ates, including Schuyler Com - mons, a 144-unit community in Utica, NY; Glenmont Abbey Village, a 148-unit community near Albany, New York; and Hanover Place, a 150-unit community in the Chicago suburb of Tinley Park, IL. “We studied this sector for a long time; it dovetails well with our prior experience. These acquisitions are consistent

with our investment strategy of building a defensive core and core-plus portfolio that focuses on fundamental needs of consumers, like housing for one of the largest segments of the U.S. population, while offering residents value as well as quality,” said Peter Scola , founder and co-CEO of Livingston Street Capital. Scola notes that as of this year, all members of the Baby Boomer generation, which totaled 71.6 million in 2019, are at least 55 years old. Stra - tegically leveraging this gen - eration’s strong demand for active, autonomous lifestyles, Livingston focuses on active adult 55+ and independent liv - ing and does not invest in as - sets that provide care. MAREJ

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