Strawberry Hill House, Vico Road, Dalkey, Co Dublin

christiesrealestate.com/eng/ … l-house-ie
€6,500,000 - c. 7500sqft / 0.75 acres

Will be in tomorrow’s IT: irishtimes.com/life-and-styl … -1.2765756

Bit of a mish-mash, but good width (therefore lots of good seaviews from most/many rooms). One very bizarre aspect, however:

I feel like for 6.5 million I’d want the entire house, and not have someone living underneath me :open_mouth:

For 6.5 million I would like a house that doesn’t look like an apartment block.

Actually on reflection I think that this property has potential as a great PIN project.

Basically we set up a company (Section 110 charity of course), grab hold of approx €10 million of that cheap corporate financing supposedly sloshing around, do this place up as a block of approx 20 “luxury” apartments and sell them off pocketing a whopping profit.

I nominate @Observer35 to be in charge of setting up the legal and financing structures for this venture. I will selflessly volunteer to go on a fact-finding tour of offshore locations such as the Caymans, Bahamas etc to look for a willing postbox.

I assume that anyone who so much as hints at building anything as crass as an apartment block in Dalkey gets eaten by an enraged DLR county councillor.

They are already a good few apartment blocks around Dalkey! And two bed workers cottages as well, Dalkey isn’t all mansions.

On a different point I was out walking on the Killiney beach last weekend and parked beside the old hotel near the DART station that was converted to apartments some time back. I remarked to my other half that the developers (or maybe planners) actually did a tasteful job on that development that replaced the hotel. They could have crammed a lot more apartments on the site, covering the grass/garden area that used to be in front of the hotel, but refrained.

(1) Done, for €40 have set up PIN Acquisitions with CRO.

(2) Instead of paying €6.5m to the vendors, we will “create” a valid loan against the property for them (drafted by our lawyers), with a face value of €10m
(won’t go into the details of this on the PIN, but while specific steps need to be followed, is easy to do).

(3) We fund PIN Acquisitions with €6,499,999 via “Profit Participating Loan Notes” and €1 of equity.

(4) Ownership of these PPLNs will be held in trust for a Cayman Islands company (don’t to set it up yet, wait until end).

(5) PIN Acquisitions will then buy the loan for €6.5m.

(6) We just put a line in our accounts that PIN Acquisitions is a Section 110 Company under the 1997 TCA (+notify Revenue).

(7) We will get some friends an family to be our Directors (don’t need an Irish Charity as we are not US citizens).
(they will sign side letters stopping them from doing anything, and we keep all copies with our lawyers).

(8) Any income / gain we get on the property will be “structured away” via interest on our PPLNs to the Cayman Islands.

(9) We will ensure we make a €1,000 per annum profit so that we incur €250 tax (ensures we can close a tax return)

(10) When we are ready (now, or in 10 years time), we foreclose on the loan (our loan agreement will ensure that the owner could never re-posses the asset), and sell the asset. All the proceeds will go via our PPNs to the Cayman Islands.

zero Irish tax on any rental income or capital gain (apart from the €250 per annum needed to file a closed tax return).

PS: costs of accounts (5,000k per annum), and getting lawyers to draft water-tight loan agreement with vendor (20,000), and foreclose properly at the end (5,000), and set up Cayman vehicle (25,000), will be more than covered by the fact that as a Section 110, PIN Acquisitions will not have to pay any Stamp Duty (almost 120,000).

8DD

PS: of course, that is the DIY version. if we think the Irish taxes avoided get to be much bigger amounts (i.e. another Celtic tiger boom comes along, and our property becomes worth +€30m), then we might be well advised to hire the A-team (like the vultures use; who created this vehicle and got the Revenue to make it work domestically), just to be sure:
thepropertypin.com/viewtopic.php?p=887283#p887283

cant see where the apartment fits. Big minus for this property.