Jerry S. Williford

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  www.byomortgage.com/library.html?nid=134&category=newsl - [Cached Version]
  Published on: 4/9/2007    Last Visited: 4/9/2007  

  "If it's an interest expense, then the borrower would most likely have an ordinary tax deduction," said Jerry Williford, a tax executive director with the Grant Thornton office, an accounting advisory firm. "On the other hand, if the lender is deemed to be a partner with the borrower, then the lender will have less capital gain on sale and the tax effect can be significant."
  
  He noted that IRS rules and court cases in the past involving SAM arrangements indicate the borrower and lender are not partners for tax purposes. "Taxpayers should be aware that the IRS could raise the issue and argue that the lender is a partner with the borrower with the payment of the share of appreciation not being deductible as interest," Williford said.

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  www.tax-news.com/asp/story/Grant_Thornton_Urges_US_Firm - [Cached Version]
  Published on: 8/29/2007    Last Visited: 8/29/2007  

  "To the surprise of many partners, the capital accounts referred to in their partnership or LLC agreements are Section 704(b) capital accounts - not GAAP or tax," explained Jerry Williford, a senior manager in Grant Thornton's tax practice.

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  2007 archived press releases - Grant Thornton LLP - [Cached Version]
  Published on: 12/5/2007    Last Visited: 11/9/2008  

  "To learn how these tax tips may apply to your real estate business, please contact your tax advisor," said Jerry Williford, tax senior manager in Grant Thornton LLP's real estate industry practice.
  
  Grant Thornton's Construction, Real Estate and Hospitality Industry group has developed 10 tax tips for real estate developers and investors.

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  A Taxing New Finance Twist? - [Cached Version]
  Published on: 7/1/2004    Last Visited: 7/13/2004  

  "If it's an interest expense, then the borrower would most likely have an ordinary tax deduction," says Jerry Williford, a tax executive director with Grant Thornton's Charlotte, N.C., office."If the lender is deemed a partner, the tax implications become much more complex."
  
  But Williford says it seems clear from other IRS rules and court cases that in SAMs, the borrower and lender are not partners for tax purposes.He believes payment of a share of appreciation to a lender should result in an interest deduction.

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  BNA Tax Management Advisory Board Meeting Agenda - [Cached Version]
  Published on: 12/7/2006    Last Visited: 3/25/2008  

  By Jerry S. Williford, CPA and David Kaplon, CPA, Grant Thornton LLP, Charlotte, NC and Baltimore, MD

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  BNATAX MANAGEMENT - [Cached Version]
  Published on: 11/19/2001    Last Visited: 11/19/2001  

  Operator, Speculator, Investor, Developer or Dealer: The Eternal Quest for Non-Inventory Classification , by Jerry S. Williford, Esq., CPA, Charlotte, North Carolina

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  CPA\Law Forum - Triangle Chapter - [Cached Version]
  Last Visited: 2/9/2008  

  Speakers: Todd Sinnett & Jerry Williford, Grant Thornton

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  Fair Community Lending Services - About - [Cached Version]
  Published on: 3/1/2004    Last Visited: 1/11/2007  

  "If it's an interest expense, then the borrower would most likely have an ordinary tax deduction," said Jerry Williford, a tax executive director with the Grant Thornton office, an accounting advisory firm."On the other hand, if the lender is deemed to be a partner with the borrower, then the lender will have less capital gain on sale and the tax effect can be significant."
  
  He noted that IRS rules and court cases in the past involving SAM arrangements indicate the borrower and lender are not partners for tax purposes."Taxpayers should be aware that the IRS could raise the issue and argue that the lender is a partner with the borrower with the payment of the share of appreciation not being deductible as interest," Williford said.

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  Home Guide - [Cached Version]
  Published on: 6/11/2004    Last Visited: 6/12/2004  

  "If it's an interest expense, then the borrower would most likely have an ordinary tax deduction," said Jerry Williford, a tax executive director with the accounting firm of Grant Thornton.
  ...
  "Taxpayers should be aware that the IRS could raise the issue and argue that the lender is a partner with the borrower with the payment of the share of appreciation not being deductible as interest," Williford said.

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  HousingZone.com - News - [Cached Version]
  Published on: 6/7/2004    Last Visited: 6/7/2004  

  "If it's an interest expense, then the borrower would most likely have an ordinary tax deduction," said Jerry Williford, a tax executive director with the accounting firm of Grant Thornton.
  ...
  "Taxpayers should be aware that the IRS could raise the issue and argue that the lender is a partner with the borrower with the payment of the share of appreciation not being deductible as interest," Williford said.

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