As of this morning, it looks as if the lawyers for Chilean mining magnate Andronico Luksic Craig decided not to renew, or simply neglected to renew, the District of Columbia business license for Tracy DC Real Estate, Inc., the company that owns the Kalorama Triangle mansion rented by Jared Kushner and Ivanka Trump. (For some background, see this post.) A search for the license on the District of Columbia’s Department of Consumer and Regulatory Affairs site conducted yesterday at 9:43AM — on the day the license was set to expire — showed that it was “ready to renew.”

Today, the same search yields no records.

A search for Tracy DC Real Estate’s corporate information on the DC Business Center site shows the same thing: the entity is active, but does not have a Basic Business License or “BBL.”

So it’s possible that Tracy DC Real Estate is no longer carrying a business license for the Kalorama mansion, and has been unlicensed in DC as of midnight last night. (District of Columbia municipal regulations require all landlords to have a business license. Those without one cannot legally demand that tenants pay their rent and may incur fines.) It seems equally likely that there is something about the way the system processes renewals that accounts for the disappearance of Tracy DC Real Estate licensing information.

I wasn’t able to learn much one way or the other when I called the Department of Consumer and Regulatory Affairs this morning and inquired about the lack of search results. The clerk told me the license had probably disappeared from the search because the license simply had not been renewed, but, he added, there is always a chance the paperwork is still “in the mail” and the renewal just hasn’t been processed.

In the mail? The DCRA site offers online renewal services, and it seems odd that Luksic’s attorneys, or Tracy DC Real Estate’s corporation agent, CT Corporation Services, would not have taken advantage of that. These are not people who let things lapse or go about their affairs in a careless or haphazard way. (Public records show, for example, that they have scrupulously kept up with property tax payments, incurring no penalties since taking ownership. The next tax payment on the Kalorama mansion — $22,540 — is due on March 31, 2019.*)

As the Twin Metals timeline indicates, Tracy DC Real Estate was formed on December 15, 2016, the same day as Department of Interior Solicitor Hillary Tompkins issued her M-Opinion denying renewal of the Twin Metals leases in Superior National Forest. Corporate records show that incorporation was done by Jonathan Cohen and Richard J. Snyder of the law firm Duane Morris LLP. (Filings list the Duane Morris LLP offices on 505 9th Street NW in Washington, DC as Tracy DC Real Estate’s business address.) A Robert M. Snyder, who does not appear to work at Duane Morris, but appears to be a relative of attorney Richard J. Snyder, is listed as the “governor” of the corporation.

Richard J. Snyder’s bio on the Duane Morris site makes it clear that setting up the business end of the Kalorama Triangle mansion is just one of several matters he handles for the powerful Luksic family. For this same “Forbes 100 listed South American family and certain Liechtenstein-owned U.S. entities,” Synder also handled a “$50 million unsecured loan and mortgage financing involving 14 properties in three states with attendant U.S. tax advice.”** He advised unnamed “South American investors” and a “related Lichtenstein establishment” on corporate restructuring of $72 million in real estate and other assets in six jurisdictions, including France, Panama, Peru, Massachusetts, Florida, and Colorado.

I can’t say what these loans and restructurings are all about, and whether they have any connection to the Boundary Waters reversal story I’ve been pursuing. The Colorado matter, for instance, might simply have to do with Andronico Luksic’s home in Aspen. But it’s pretty clear that these South American and Lichtensteinian matters are all Luksic Group matters. The Luksic and Fontbona families conduct much of the Luksic Group business, including their control of mining conglomerate Antofagasta, Plc, and Quinenco, S.A., an investment firm, through Lichenstein-based vehicles.

It seems unlikely, but not out of the realm of possibility, that an attorney entrusted with such grave responsibilities would overlook the simple renewal of a business license. Especially not with such high profile tenants in the mix. If this is indeed an oversight or a matter of waiting for the DCRA system to update, it will probably be corrected in the next few days. If not, it could be a signal that the Kalorama property is going to be put on the market, or transferred to some other entity, and that something else is afoot.

Update 7 March 2019. One week on, and no license renewal. It is hard to avoid the conclusion that the group behind Tracy DC Real Estate, having gotten what it wanted, or all it’s going to get from this administration, no longer sees any need to keep up appearances, or pretend that the rental ever was a legitimate business arrangement. Non-renewal of the business license strongly suggests that the Kalorama mansion should be looked upon as a foreign emolument.

*Update 26 March, 2019. Still no record online of the Tracy DC Real Estate business license renewal, but the property taxes for the first half of 2019 have been paid. And on 20 March, the corporation filed a biennial report with the District of Columbia Department of Consumer and Regulatory Affairs. These reports are due by April 1st of each second calendar year. They appears to be keeping up with everything except the business license.

**Update 5 May 2019. This financing activity may have included the Kalorama mansion. On April 5th, 2018, Rodrigo Swett signed a Deed of Trust for 2.75M on the property at 2449 Tracy Place NW. On the same day, he signed similar instruments for multiple properties in Miami Beach and at least 7 properties in Boston’s Back Bay. That would seem to cover the “three states” (Florida, Massachusetts, and District of Columbia) to which Synder refers in his bio.

Update 9 June 2019. The business license for the mansion was renewed on 31 May, 2019, a full three months after it was allowed to expire.

What accounts for the three month lapse? An oversight by Luksic’s lawyers seems the most likely explanation. Or maybe, after borrowing against the property in April 2018, the owners planned to change its status, then decided to stay the course.

Read other posts about the Boundary Waters reversal here.