Top-tier modeling environment for sophisticated practitioners. Build the capital stack, configure the distribution waterfall, classify debt under § 752, configure § 704(b) and § 704(c) allocations (with all three methods compared side-by-side), layer state tax overlays, run sensitivity, and export a term sheet — all in one place. Designed for real estate principals, developers, sponsors, and the counsel and CPAs who advise them. Used inside the firm; available to RESERVE members.
RESERVE members access the full tool through their member dossier at /reserve/, behind firm authentication. If you would like to engage the firm at the RESERVE tier or have us run a deal through the tool for you, contact us directly.
Unlimited member classes with independent capital, preferred return rate, profit share, loss share, voting rights, and transfer restrictions.
Configure the distribution mechanics with the precision a modern deal requires.
Member debt classification and allocation, integrated with the deal economics.
Capture the structural framework that becomes the operating agreement.
50 states plus DC with marginal income tax rate, capital gains rate, and conformity flags for § 168(k) bonus, § 163(j) interest limitation, § 461(l) excess business loss, and § 199A QBI. PTET election availability flagged where applicable.
Verdict card with PENCILS / MARGINAL / DOES NOT PENCIL output. Sources & uses table. Returns by class with MOIC and IRR. Waterfall trace tier-by-tier. 5×5 sensitivity heat map flexing exit price and hold period. Structural diagram. Notes engine surfacing securities, § 752, dealer-property, and state-conformity issues automatically. Save / load JSON, print summary, export term sheet for circulation.
Six phases. Phase I is live to RESERVE members today. Each subsequent phase deepens capability on a discrete dimension — allocation engines, blocker structures, REIT and OZ compliance, structural diagram editor, and tax-overlay refinements.
Capital stack, waterfall engine, member debt, governance, state selector, sensitivity, save/load, term sheet export.
Targeted capital accounts vs. substantial economic effect; traditional, curative, and remedial § 704(c) methods compared side-by-side.
Domestic and foreign corporate blockers, REIT-blocker for tax-exempts, FIRPTA at the investor level, § 514 UBTI with fractions rule.
Full REIT income/asset/distribution engines, QOF 90% test, QOZB 70% test with working capital safe harbor, TIC Rev. Proc. 2002-22 conditions.
Interactive drag-and-drop structure editor with blocker entities, parallel feeders, tax-classification badges. Branded PDF export with methodology footnotes.
§ 163(j), § 461(l) with 2026 threshold, § 199A with rental safe harbor, multi-state apportionment and sourcing, PTET modeling by jurisdiction.