A tax abatement granted to induce downtown development transferred automatically to the buyer when the developer sold — with no clawback provision and no public notice.
What this case study shows: The DDA used a Bond for Title structure — a Georgia arrangement where the DDA takes nominal title to a property to qualify it for a tax exemption, while the developer retains beneficial ownership and pays a reduced fee in lieu of full property taxes. This abatement automatically extends to any subsequent owner during the abatement term. DeKalb County deed records confirm that nearly three months before the public announcement, the City of Avondale Estates received real property from the developer and four bilateral agreements were executed between the city and the seller — none of which appears in publicly available reporting or in accessible DDA or BOMC meeting records reviewed for this case study. The transaction was structured as a lease assignment rather than a property sale, a mechanism that required no public review process. The abatement — a public subsidy designed to induce development — became a capitalized private asset. DeKalb County Schools, which held no vote on the abatement structure, bore approximately $1.47M of the present-value cost.
Willis Avondale Estates Apartments. 2700 College Avenue E, Avondale Estates, Georgia. DeKalb County Parcel ID: 15 248 04 014. 197 units, five stories, built 2018. Located outside the Avondale Estates Tax Allocation District boundary.
The building is listed in DeKalb County records with the Downtown Development Authority of Avondale Estates as owner of record — reflecting the Bond for Title structure under which the DDA holds nominal title during the abatement period, with the developer retaining beneficial ownership.
The site was assembled from predecessor commercial parcels along East College Avenue — auto shops, tire stores, and used car lots that had been annexed into Avondale Estates from unincorporated DeKalb County in 2012. The primary parcel assemblage was purchased from the previous owner for approximately $4.575M in January 2017, the same month the Bond for Title was executed.
Under Georgia's Bond for Title arrangement, a DDA acquires title to a property, making it exempt from property taxes as a government-owned asset. The developer pays a fee to the DDA in lieu of taxes, typically structured to ramp up toward market-rate taxation over the abatement period. At the end of the term, title transfers back to the developer or its successor.
The DDA's own public FAQ (exploreavondale.org, 2018) described this structure and stated that the abatement was designed to make development economically viable on what had been a surface parking lot and vacant land. The project's developers — South City Partners and ELV Associates — received a $25.5M construction loan from Cadence Bank in 2017.
The abatement term is approximately 2019 through 2029. The applicable percentage of fair market value subject to taxation increases by 6.5 percentage points per year, beginning at 35% in year one and reaching 93.5% in year ten, as confirmed in Schedule 3.2.1 of the original bond resolution. Taxable value ramps toward full assessment accordingly.
The public announcement of the sale appeared on February 5, 2020 — the day the transaction closed. What the deed records show is that the transaction had been substantially structured nearly three months earlier — 84 days before public disclosure, counting from November 13, 2019.
On November 13, 2019 — recorded in the DeKalb County deed records on November 18, 2019 — the following instruments were executed under the Willis Apartments filing:
The buyer's acquisition financing — a $44,125,000 loan from Citizens Bank — was also recorded in connection with the same transaction package (Deed Book 28092, Page 59).
Pre-positioning transaction documents weeks or months before a commercial real estate closing is standard practice; lien releases, lease amendments, and bilateral agreements are routinely executed and held pending final wire transfer. What is notable here is not the timing but the absence of any public notice requirement at any point in the process — before, during, or after closing.
Because the Bond for Title structure holds legal title in the DDA's name, the $52.5M transaction was recorded not as a property sale but as a lease assignment. No deed transferring ownership to the buyer appears in the public record. This is the mechanism by which the transfer required no public review: under the Bond for Title structure, it was a change of leasehold interest, not a change of ownership.
SEDCO Capital, the co-buyer, is the asset management arm of SEDCO Holding Group, a Saudi private family wealth management firm founded in 1976. It is not the Saudi government's Public Investment Fund (PIF), which is a separate sovereign wealth entity. SEDCO Capital manages Shariah-compliant real estate and private equity investments.
The following table shows annual abatement benefit calculated from DeKalb County tax records for PARID 15 248 04 014. "Tax Without Abatement" reflects what would be owed at the applicable millage rate on the assessed value without abatement and is calculated from confirmed inputs. "In-Lieu Payment" reflects actual payments confirmed from portal records. "Annual Subsidy" is the calculated difference.
| Year | Assessed Value | Tax Without Abatement (calc.) | In-Lieu Payment (actual) | Annual Subsidy (calc.) | Recipient |
|---|---|---|---|---|---|
| 2018 | $6,647,680 | $309,343 | $0 | $309,343 | Developer |
| 2019 | $16,985,800 | $790,417 | $0 | $790,417 | Developer |
| 2020 | $19,800,000 | $923,630 | $323,271 | $600,360 | Buyer (from Feb 5) |
| 2021 | $19,800,000 | $923,630 | $377,341 | $546,289 | Buyer |
| 2022 | $19,800,000 | $923,630 | $437,802 | $485,829 | Buyer |
| 2023 | $21,200,000 | $964,833 | $525,834 | $438,999 | Buyer |
| 2024 | $20,800,000 | $953,326 | $581,529 | $371,797 | Buyer |
| 2025 | $20,800,000 | $972,234 | $557,819 | $414,415 | Buyer |
| Developer total (2018–Feb 2020) | — | ~$1,099,760 | ~$0 | ~$1,099,760 | |
| Buyer total (Feb 2020–2025) | — | ~$5,664,283 | ~$2,803,596 | ~$2,861,449 |
Source: DeKalb County Tax Records, Parcel ID (PARID) 15 248 04 014. Combined millage rate ranges from 46.648 mills (2020) to 46.742 mills (2025); confirmed year by year from actual tax bills. Assessed value = 40% of appraised fair market value per Georgia law. In-Lieu Payment figures are from confirmed portal records. Tax Without Abatement and Annual Subsidy are calculated from confirmed inputs. In 2018 and 2019, every property tax line billed at $0.00 — city taxes, county operations, school operations, fire, and all others. The only charge in those years was a flat $636 stormwater fee, assessed identically regardless of property value. Abatement runs through 2029; projected remaining subsidy approximately $734K based on the schedule confirmed in bond resolution Schedule 3.2.1.
NPV — net present value — is the current dollar value of a stream of future payments, discounted to reflect the fact that money received in the future is worth less than money in hand today. The table below calculates what the remaining abatement payments were worth at the time of the February 2020 sale, at different discount rates.
At the time of the February 5, 2020 sale, the remaining abatement benefit (2020 through 2029) had a present value of approximately $2.97M to $3.05M, depending on discount rate assumption. This value transferred to the buyer at closing — without any clawback provision or public notice.
| Discount Rate | NPV of Post-Sale Abatement |
|---|---|
| 5% | $3,047,130 |
| 6% | $2,967,323 |
| 7% | $2,891,705 |
Property taxes in this jurisdiction are levied by three separate entities: the City of Avondale Estates, DeKalb County, and the DeKalb County School District. The Bond for Title structure applies to all three automatically — the DDA's authority to grant abatements binds each taxing entity without a separate vote from any of them.
| Taxing Authority | Share of Millage | NPV of Post-Sale Cost (6%) | Vote on Abatement |
|---|---|---|---|
| City of Avondale Estates | ~21.1% | $627,140 | Implicit (via DDA authority) |
| DeKalb County | ~29.4% | $872,042 | None required |
| DeKalb County Schools | ~49.5% | $1,468,141 | None required |
The school district paid the largest share and had no vote. Georgia law permits municipal DDAs to use Bond for Title structures that bind all taxing authorities within the municipality, including independent school districts. The DeKalb County Board of Education was not consulted and had no legal avenue to object. The $1.47M present-value cost to DeKalb County Schools was incurred as a direct consequence of the DDA's abatement decision and the subsequent sale.
The City of Avondale Estates' own website states that because Willis is outside the Tax Allocation District, "100% of increased city tax revenue goes to the general fund" — distinguishing it favorably from TAD-area properties, where increment is captured by the TAD fund.
The statement is literally true and materially incomplete. The DDA simultaneously reduced what that 100% actually is — instead of the property generating approximately $790,000 in full-rate taxes in 2019, it contributed zero in property taxes that year.
In October 2025, the DDA Chair published a response to public criticism of the city's abatement program on the city's official website:
"I chuckle when I hear it said that the city is taking a loss with these abatements. The simple fact is that the city collected dramatically more tax from each of these properties before the improvements in the FIRST YEAR of the schedule — and the tax goes up 6.5% every year."
The DeKalb County tax portal allows anyone to verify this claim against the actual records for parcel 15 248 04 014.
In 2018, every property tax line on the Willis parcel — city taxes, county operations, school operations, fire district, hospital, bonds — shows the same figure: $0.00 billed. The only charge that year was a flat $636 stormwater fee, assessed identically regardless of property value. In 2019, the result was identical: $0.00 in property taxes.
The Willis property — which would sell fourteen months later for $52,500,000 — generated zero property tax revenue in its first two full years on the tax rolls.
The first year of meaningful revenue was 2020, when the in-lieu payment reached $323,271. By that date, the original developers had already closed the sale. That payment, and every subsequent payment through 2029, flows to Coastal Ridge Real Estate and SEDCO Capital — not to the taxing authorities that granted the abatement.
The statement is accurate in one narrow sense: the abatement schedule does ramp upward each year, and by year ten the property will approach full-rate taxation. But the baseline it ramps from is zero — not, as the framing implies, a robust pre-development tax contribution that the city generously agreed to forgo. The predecessor parcels were auto shops and tire stores assembled by an owner publicly reported as delinquent on more than $71,000 in property taxes at the time of annexation. The consolidated Willis parcel generated no property tax at all in 2018 or 2019.
The city's share of the year-one in-lieu payment — at 9.55 mills out of 46.7 combined — is approximately $66,000. The school district waited two full years to collect a dollar from a property now worth $52 million, then watched the payment stream transfer to a new private owner before the abatement had run half its term.
The abatement was structured to induce a specific outcome: quality mixed-use development at the western gateway of Avondale Estates' central business district. That outcome was delivered by South City Partners and ELV Associates, who assembled the site, obtained financing, managed construction, and opened a 197-unit apartment building in 2018.
Of the confirmed $4.6M in total abatement benefit across the full term, South City Partners collected approximately $1.1M — roughly 24% — before selling the property fourteen months after opening.
The remaining 76% transferred to Coastal Ridge Real Estate and SEDCO Capital: approximately $2.86M in confirmed benefit through 2025, plus a projected ~$734K through the 2029 expiration, based on the abatement schedule confirmed in the original bond resolution.
Coastal Ridge and SEDCO Capital did not build anything in Avondale Estates. They acquired a stabilized asset in a strong market. The governance structure that administered the abatement contained no mechanism to distinguish between these two outcomes.
The $52.5M transaction was not recorded as a property sale. Because the DDA held legal title under the Bond for Title structure, what transferred on February 5, 2020 was a leasehold interest — recorded as a lease assignment, not a deed. No deed of sale appears in the public record.
DeKalb County deed records confirm that nearly three months before the public announcement, the City of Avondale Estates received real property from the developer and four bilateral agreements were executed between the city and the seller. The DDA Chair signed closing documents as Ground Lessor on February 3, 2020. None of these instruments appear in publicly available reporting or in accessible DDA or BOMC meeting records reviewed for this case study.
Pre-positioning transaction documents weeks or months before a commercial real estate closing is standard practice; lien releases, lease amendments, and bilateral agreements are routinely executed and held pending final wire transfer. What is notable here is not the timing but the absence of any public notice requirement at any point in the process — before, during, or after closing.
The bond resolution confirmed in Schedule 2.3 that the DDA collected a $350,000 administrative fee from the developer at the original 2018 closing.
The governance framework that administered the Willis abatement required no independent assessment of whether the abatement was necessary to induce the development. It required no clawback provision if the property sold within the abatement term. It required no notice to DeKalb County Schools — which bore approximately 49.5% of the abatement cost — before, during, or after the transaction. It required no public vote or noticed meeting before the DDA Chair executed lease assignment documents. It required no deed of sale to be recorded when the $52.5M transaction closed, because the Bond for Title structure held legal title in the DDA's name throughout.
None of these are accusations of misconduct. The officials involved were volunteers acting within the law. The transactions were legal. The structural gaps are the subject of this case study — and they apply to every Bond for Title abatement administered by every small city DDA in Georgia, not only this one.
Abatement Clawback Provision. Bond for Title and similar abatement arrangements should include a mandatory clawback clause: if the property sells within the abatement term, the present value of the remaining abatement stream is shared proportionally with the affected taxing authorities. The developer receives the inducement value for which the abatement was granted — the development itself. Windfall value from a quick sale at a stabilized cap rate is a separate event. Public subsidies should not be freely transferable private assets.
Transaction Transparency Requirement. Any transfer of a leasehold interest in a Bond for Title property — regardless of whether legal title moves — should require notice to all affected taxing authorities and a noticed public meeting before the DDA executes closing documents. Structuring a $52.5M transaction as a lease assignment to avoid public review is a consequence of the current framework's silence on this point. That silence should be closed.
Read the Full Reform Framework →
DDA's own public FAQ describing the Bond for Title structure, abatement rationale, and statement that Willis is outside the TAD. States that "most if not all future developments will be in the TAD area." Source: exploreavondale.org.
News report of the sale, including the full Cushman & Wakefield press release. Confirms sellers (South City Partners and ELV Associates), buyers (Coastal Ridge Real Estate and SEDCO Capital), sale date (February 5, 2020), and 92.4% occupancy at time of sale. Source: Decaturish.com.
Official deed records confirming the pre-closing transaction package. Search parcel 15 248 04 014 or grantor "SCP Avondale" to retrieve the lease amendment (Book 27931/152), warranty deed to city (27931/160), four bilateral agreements (27931/165–190), and Cadence Bank lien release (27931/157). The February 3, 2020 closing joinder — DDA as Ground Lessor, Citizens Bank as lender — is at Book 28092/59. Source: DeKalb County Clerk of Superior Court.
Official county assessment and payment records confirming DDA ownership, annual assessed values, and in-lieu-of-tax payments 2018–present. Millage detail for 2018 and 2019 confirms every property tax line billed at $0.00. Search parcel ID 15 248 04 014. Source: DeKalb County Tax Commissioner.
172-page bond resolution adopted by the DDA authorizing the Willis project. Contains Schedule 3.2.1 (Savings Schedule confirming the 6.5% annual abatement ramp), Schedule 2.3 (Letter Agreement confirming the $350,000 administrative fee), and the full Lease Agreement including Exhibit B (Valuation of Leasehold Interest). Source: exploreavondale.org.
The DDA Chair's public defense of the abatement program, including the claim that "the city collected dramatically more tax from each of these properties before the improvements in the FIRST YEAR of the schedule." Source: avondaleestates.org.