The Corporate Shield Liability
Multi-layered CRE holding structures face catastrophic exposure as the IRS aggressively scrutinizes intercompany transactions for Section 482 transfer pricing anomalies. Administrative friction—like government delays in issuing entity EINs—freezes operational bank accounts and forces sloppy, retroactive intercompany billing. This creates a discoverable paper trail that auditors and litigators use to pierce your liability shield. Simultaneously, multi-year development projects suffer from silent cost-index drift, leaking operating margins directly to unmitigated material inflation.