Maybe there is some advanced tax planning / entity structuring ideas here...
My clients, two brothers, own two business together - both 50/50. One is a C-Corp retail operation. The other is an LLC (partnership) that owns a commercial building. The commercial building is unrelated to the retail operation.
One brother wants to retire and they want to structure so that the retiring brother will get 100% of the LLC and the non-retiring brother will get the C-Corp. Can you think of a way to conduct this exchange tax free?
I have thought about electing C-Corp status for the LLC in order to do a tax free reorganization, but before I even figure out if this will meet the requirements, this idea breaks the rule of putting real estate in a corporation.