Green Tax Break Syndicated Easements Face IRS Scrutiny

Jack Fisher has raised hundreds of millions of dollars pitching investors on real estate development projects that were never built. Fisher, an accountant-turned-developer, promoted projects such as the Preserve at Venice Harbor, near Hilton Head, S.C., where marketing illustrations showed houses on canals that evoked the famous Italian city. Instead of developing the land, he recruited investors to elaborate deals that provided them charitable tax deductions in return for donating easements for conservation.

The Internal Revenue Service, however, suspects the deals may amount to tax fraud. Fisher is at the center of a criminal probe related to these syndicated conservation easements, according to people familiar with the details, who requested anonymity to discuss a confidential matter. The investigation has already led to tax conspiracy charges against three accountants who worked with him.

A syndicated conservation easement gives dozens of investors in partnerships three choices: to build a specific development project; to hold on to the land and build later; or to donate an easement to a land trust or government, promising to forgo development. The third option entitles investors to charitable tax deductions, based on the appraised value of the land, that can be worth four or five times their investment.

Easements have been used—legitimately, and mostly by family partnerships and individuals like farmers—for decades as part of a federal push to preserve more than 30 million acres of land. Those aren’t the focus of an IRS crackdown. Instead, it’s going after promoters like Fisher who sell deals through brokers, accountants, lawyers, and tax preparers, and who market the projects that generate large tax deductions. The IRS has made these an enforcement priority, suing some promoters to shut them down and criminally investigating others.

California conservation lawyer Misti Schmidt says a typical syndicated easement used by wealthy investors is an “ugly tax-shelter scheme” that relies on grossly overvalued appraisals. “There’s so much money to be made, they just keep doing it,” says Schmidt, a partner at Conservation Partners.

Those appraisals are at the center of the legal fight around syndicated easements. Before an easement donation is made, an appraiser assigns it a value based on its highest and best use. That number is then used to calculate the tax deductions. The IRS often argues that those appraisals vastly inflate the development potential of a property, and that promoters use those valuations to market lucrative tax deductions.

Two of Fisher’s associates, the brothers Stein and Corey Agee, pleaded guilty in December to conspiring to promote fraudulent tax breaks and are cooperating with prosecutors. Although Fisher wasn’t charged or named in the Agee cases, he’s referred to as Promoter A in court documents, the people familiar with the details say. Documents reviewed by Bloomberg confirm Fisher’s role in the deals. Lawyers for Fisher didn’t respond to emails and phone calls seeking comment.

In the Stein Agee case, prosecutors say the deals were “illegal tax shelters that allowed taxpayers to buy tax deductions,” according to the charges. Appraisals were “falsely inflated,” while the conservation option was “always a foregone conclusion.” Many investors signed up after the tax year in which easements were donated, prosecutors say, even though the IRS allows deductions only in the same year a donation is made. Promoter A and others had investors backdate checks and agreements, according to the charges.

“Promoter A’s tax shelters resulted in a massive evasion of taxes,” the charges state. In all, more than 1,500 investors received $1.2 billion in fraudulent tax deductions, prosecutors said. At one point, Promoter A told Stein Agee that he met with several co-conspirators to make sure they were on the “same page” about late investments, according to the charges. Promoter A proposed that Agee could falsely suggest that backdated checks weren’t deposited because they were “lost” on someone’s desk. Lawyers for the Agees declined to comment.

Nationwide, the IRS has challenged $21 billion in tax deductions claimed for syndicated easements from 2016 to 2018, saying it’s auditing 28,000 taxpayers. Former President Donald Trump has donated several easements, including two under scrutiny by New York state authorities.

“The IRS fully supports the benefit of legitimate conservation easements around this country,” IRS Commissioner Charles Rettig told Congress in March. “It has done tremendous things for farmers and others. Our problem is with the abusive syndicated easements.”

The IRS crackdown comes amid a battle in Congress that pits conservation groups and national appraisal organizations against promoters of syndicated easements. Conservation groups want legislation that would bar investors from claiming deductions worth more than two and a half times their initial investment. Promoters have been blocking that fix for years.

“The IRS’s current take-no-prisoners litigation strategy is also going after minor technical flaws that arise in all easements, not just syndications,” says Schmidt, the conservation lawyer. “Legitimate easements are now getting disallowed.”

Fisher, who’s in his late 60s, grew up on a small-town farm in Marshall, N.C., and still speaks in a soft Southern drawl. The son of a truck driver and homemaker, he graduated with a degree in accounting from nearby Mars Hill College in 1974 before joining the IRS. Fisher then became a certified public accountant, worked for Price Waterhouse, and joined a firm that moved him to Atlanta to work with the National Football League’s Falcons.

Later, he took a job at an accounting firm with the Agee brothers’ father, Edward Agee. “I got a lot of good experience,” Fisher testified at a trial after a real estate broker sued him, claiming the developer owed him a commission. Fisher said he met people who “could refer you to business: bankers and things like that.”

He got into development by auditing construction companies, and later began assembling his own investment deals, founding Preserve Communities about two decades ago.

Fisher was adept at raising money, says Anthony Antonino, a real estate consultant who helped with the sale of 800 acres in North Carolina for $14.75 million to entities controlled by Fisher and a wealthy investor. “Jack knows where the money’s at, and he knows how to get it,” Antonino says.

Some of Fisher’s wealthy investors were involved in equestrian events, say people familiar with the matter. His family owned a 40-acre show stable in Alpharetta, Ga., according to a 2013 story in the Atlanta Journal-Constitution. His then-wife, Libba, and two of their children won several titles competing in elite hunter and jumper events, according to records maintained by the U.S. Equestrian Federation.

He was a hands-on developer, says Mark Brooks, a civil engineer who helped Fisher build projects. “He was out there walking the roads and figuring out site lots,” Brooks says. “He was real proud when he did the developments. He felt he was doing things to help out Madison County, which was a pretty poor county.”

He also branched out to the Western U.S., buying a 1,088-acre ranch near Reno, Nev. In late 2018 a Georgia corporation Fisher formed donated an easement covering 812 acres to the North American Land Trust. Investors got $51.2 million in deductions, according to court filings. They put up $10 million, his partner told planners in Nevada’s Washoe County.

Months later, Fisher pursued permission to develop 38 homes on land not covered by the easement. He showed up at a rural advisory board meeting in July 2019 wearing a cowboy hat and flanked by ranch hands, according to a resident. When pressed, Fisher backed down.

“We have no plans to do anything with that property other than to make it part of the ranch,” Fisher said at the recorded meeting. In the face of stated opposition by planners, he withdrew his application.

The Agee brothers, whose father died in 2009, helped promote some of Fisher’s deals. At the proposed Preserve at Venice Harbor development, $179.8 million in tax deductions were claimed by the 390 investors who chose a conservation easement instead of building homes, court documents show. That was more than four times what they put in.

By 2018, less than two years after the IRS began targeting syndicated easements as tax shelters, Fisher was under investigation, the people with knowledge of the matter say. “You have to be very, very careful that these look like real estate investments as compared to, you know, basically a tax shelter,” Promoter A told an agent posing as an investor, according to the charges against Stein Agee.

Fisher continued to work with the Agees through last year, the people say. In November, Promoter A left a handwritten note for Stein Agee saying he’d been “cleaning up the books,” the charges state. About the same time, a video was uploaded to the Preserve Communities Vimeo account.

Fisher talks about his career while viewers see images of forests, mountains, and rivers, and of Fisher himself sitting on a deck, and then feeding a horse. “I hope the people who live in our communities gain a greater connection to nature, to slow down in life, to realize what’s really important,” he says. “We only have so many years here on the planet, and feeling good about what you’ve done with your life.”

— With assistance by Kaustuv Basu, Neil Weinberg, and Elise Young

By: David Voreacos

Source: Green Tax Break Syndicated Easements Face IRS Scrutiny – Bloomberg

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How Investing in Strategic Partnerships Can Help Grow Your Business

How Investing in Strategic Partnerships Can Help Grow Your Business

The best entrepreneurs understand the power of people. Whether thinking about accessible healthcare or, more broadly, startup success, collaboration and partnerships have always been vital, even before the pandemic strengthened the need for a collective approach.

Of course, for entrepreneurs looking to scale their business, cash is a critical piece of the puzzle. For obvious reasons, access to capital enables a business to grow, whether that’s investing in research and development (R&D), expanding overseas, or hiring top talent.

But capital shouldn’t be treated as a silver bullet. Instead, founders should turn their attention toward creating strong, strategic partnerships to drive business growth. Working with other established organisations builds credibility, allowing businesses to make further connections and expand their operations.

Entrepreneurs, though, should learn exactly how to unlock beneficial relationships that will ultimately set them up for long-term victory. Partnerships must be win-win and goals aligned so that everyone comes out as beneficiaries.

Why connections matter.

When executed wisely, strategic partnerships can foster business growth. With the potential to form a critical part of any growing business, these partnerships benefit startups and corporates alike. For large corporations, startups and scaleups can fuel innovation; for early-stage founders, big companies can enable fresh revenue, scaling possibilities and credibility.

With established partners come established networks. Existing knowledge, suppliers and customers can make selling products on a larger scale much easier to achieve. This empowers startups to scale quickly, with that revenue used to reinvest in operations and innovation, fuelling further growth and making it easier to establish new business relationships with a wider pool of organisations.

What’s also important, particularly if operating in a crowded space such as healthcare, is the potential for impact. Healthcare solutions – rightly or wrongly – are often judged by the number of patients using them. So, establishing key strategic partnerships – as we’ve done with Microsoft, Allianz and Portuguese healthcare provider Médis – provides an avenue to millions of patients.

Infermedica experimented with different business models, but eventually settled on a B2B strategy over B2C as we had the potential to reach more patients through a partnership network. This accelerated on our goal to bring more accessible healthcare to all. Strategic partnerships enable startups to quickly build credibility and cut through loud crowded markets.

Investor partnerships can play a role as well. Relationships don’t need to simply need to be between providers, but investors can bring knowledge, connections and consultancy which can help startups to overcome growing challenges and open doors that may otherwise remain closed until certain milestones around size, revenue and customers have been reached. What’s key is ensuring both sides remain committed to moving forward together.

How to unlock the opportunity.

But what’s the best way to go about creating these relationships? For founders, the first step to achieving this is to remember that although partnerships are sealed between companies, they’re created by people and that human connection has to be built first. Talk to the potential partner to understand what they are truly trying to achieve and how a partnership could help them solve it.

Similarly, founders must understand their own goals and what they need from any relationship to ensure they keep progressing towards it. When discussions are open and the people are looked after, great relationships are forged.

Developing a partner program at an early stage: creating a network of trusted resellers and innovative partners also allows entrepreneurs to explore opportunities in their immediate area and beyond. Indeed, European founders shouldn’t simply look within their own country or continent for partnerships, by looking further afield they open themselves up to new ways of thinking and opportunities.

Partner programs and ecosystems establish a feedback community, each organization provides feedback which improves each other’s offerings, leading to greater growth and credibility for all. This also drives thoughts around integration, how compatible one offering is with another to ensure it truly adds value in a real-world environment. Collaboration with partners enables entrepreneurs to see how their product fits into the bigger picture which fuels wider innovation.

For example, Infermedica’s partner program enables organizations from all aspects of healthcare to collaborate with us and access our AI technology, enhancing and diversifying services which offer better end-user outcomes. Of course, there is still some way to go and things will never stop evolving. The top SaaS companies have on average around 350 integrations as they understand all of the potential engagement points and are establishing ecosystems that reflect them. The key takeaway: when creating partner ecosystems, always keep in mind how an end-user could potentially interact with your offering.

Take your time.

As in life, building a long-last relationship takes a lot of time and effort. So, while it can be tempting to rush into an exciting partnership or program, it’s vital to take your time to build trust and establish clear boundaries. Drawing on our own experience, it took more than a year to establish partnerships with Microsoft and Allianz, and it’s an ongoing process of building mutual trust and finding new ways to collaborate.

Remember that there should be no A and B side in partnerships. Each party brings their own benefits to the table. Combining knowledge and resources makes the relationship greater than the sum of its parts, delivering greater value to customers, industry and economy.

At all times, specificity is key to success. Be sure that the partnership is truly feeding into your overall strategy and that you have all the necessary resources to support you on your journey. Plan it well and take your time. It’s a long-term strategy that requires patience, commitment and perseverance. Rome was not built in a day, but the foundations of a long lasting relationship could start tomorrow.

Keep your goals in mind and ensure you’re going into every conversation with completely open eyes because when you find those strategic connections that just work, the opportunity for growth is truly great.

By: Tomasz Domino / Chief Operating Officer, Infermedica

Source: How Investing in Strategic Partnerships Can Help Grow Your Business

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Critics:

A strategic partnership (also see strategic alliance) is a relationship between two commercial enterprises, usually formalized by one or more business contracts. A strategic partnership will usually fall short of a legal partnership entity, agency, or corporate affiliate relationship. Strategic partnerships can take on various forms from shake hand agreements, contractual cooperation’s all the way to equity alliances, either the formation of a joint venture or cross-holdings in each other.

Typically, two companies form a strategic partnership when each possesses one or more business assets or have expertise that will help the other by enhancing their businesses. This can also mean, that one firm is helping the other firm to expand their market to other marketplaces, by helping with some expertise.

According to Cohen and Levinthal a considerable in-house expertise which complements the technology activities of its partner is a necessary condition for a successful exploitation of knowledge and technological capabilities outside their boundaries. Strategic partnerships can develop in outsourcing relationships where the parties desire to achieve long-term “win-win” benefits and innovation based on mutually desired outcomes.

No matter if a business contract was signed, between the two parties, or not, a trust-based relationship between the partners is indispensable. One common strategic partnership involves one company providing engineering, manufacturing or product development services, partnering with a smaller, entrepreneurial firm or inventor to create a specialized new product. Typically, the larger firm supplies capital, and the necessary product development, marketing, manufacturing, and distribution capabilities, while the smaller firm supplies specialized technical or creative expertise.

References

Smartphones are Powerful Personal Pocket Computers – Should Schools Ban Them?

When the UK took its first steps out of national lockdown in April and schools reopened, education secretary Gavin Williamson announced the implementation of the behaviour hubs programme. And as part of this push to develop a school culture “where good behaviour is the norm”, he pushed for banning smartphones in schools.

Williamson claims that phones distract from healthy exercise and, as he put it, good old-fashioned play. And he says they act as a breeding ground for cyberbullying. Getting rid of them will, to his mind, create calm and orderly environments that facilitate learning. “While it is for every school to make its own policy,” he wrote, “I firmly believe that mobile phones should not be used or seen during the school day, and will be backing headteachers who implement such policies.”

The difficulty that teachers face is that there are often conflicting assessments of the risks and benefits of the constant influx of new devices in schools. As we found in our recent study, guidance for educators on how to navigate all this is limited. And there is no robust evaluation of the effect of school policies that restrict school-time smartphone use and there is limited evidence on how these policies are implemented in schools. So how can teachers approach this controversial subject?

We believe the best way to start is to reframe the smartphone itself. Rather than just a phone, it is more accurately described as a powerful pocket computer. It contains, among other things, a writing tool, a calculator and a huge encyclopaedia.

Join our readers who subscribe to free evidence-based news

Suggesting that children use smartphones in ways that help them learn, therefore, seems hardly radical. The perennial debate about banning phones needs to shift to thinking about how best to help schools better design school phone policies and practices that can enrich their pupils’ learning, health and wellbeing. And for that, we can start by looking at the evidence on phone use by young people.

We know that most adolescents own a smartphone. When used appropriately and in moderation, they can provide multiple benefits in terms of learning, behaviour and connection with peers. There is also evidence that technology use in classrooms can support learning and attainment.

The operative word here, though, is “moderation”. Excessive use of smartphones (and other digital devices) can lead to heightened anxiety and depression, neglecting other activities, conflict with peers, poor sleep habits and an increased exposure to cyberbullying.

Then there’s everything we don’t yet fully understand about the impact – good or bad – that smartphone use may have on children. No one does. This has been reflected in recent research briefings and reports published by the UK government: they recognise the risks and benefits of phone use, and report that it is essential that schools are better supported to make decisions about their use in school with evidence-based guidance.

Playing catch-up

To investigate existing school positions on phone and media use, we interviewed and did workshops with more than 100 teenagers across years nine to 13, along with teachers, community workers and international specialists in school policies and health interventions.

We found that teachers tend to be scared of phones. Most of them said this was because they didn’t know how pupils are using their phones during school hours. Amid pressures regarding assessment, safeguarding and attendance, phones are simply not a priority. Issuing a blanket ban is often just the easiest option.

Teachers too recognise the benefits, as well as the risks, of smartphone use. But, crucially, they don’t have the necessary guidance, skills and tools to parse seemingly contradictory information. As one teacher put it: “Do we allow it, do we embrace it, do we engage students with it, or do we completely ignore it?”

Different approaches

This is, of course, a worldwide challenge. Looking at how different institutions in different cultural settings are tackling it is instructive. Often, similar motivations give rise to very different approaches.

The mould-breaking Agora school in Roermond, in the Netherlands, for example, allows ubiquitous phone use. Their position is that teenagers won’t learn how to use their phones in a beneficial way if they have to leave them in their lockers.

By contrast, governments in Australia, France and Canada are urging schools to restrict phone use during the day in a bid to improve academic outcomes and decrease bullying.

Teachers need a new type of training that helps them to critically evaluate – with confidence – both academic evidence and breaking news. Working with their students in deciding how and when phones can be used could prove fruitful too.

Accessing information

Academic research takes time to publish, data is often incomprehensible to non-experts and papers reporting on findings are often subject to expensive journal subscription prices. Professional development providers, trusts and organisations therefore must do more to make it easier for teachers to access the information they need to make decisions.

New data alone, though, isn’t enough. Researchers need be prepared to translate their evidence in ways that educators can actually use to design better school policies and practices.

The children’s author and former children’s laureate Michael Rosen recently made the point that “we are living in an incredible time: whole libraries, vast banks of knowledge and multimedia resources are available to us via an object that fits in our pockets”.

That doesn’t sound like something educators should ignore. Findings from our study add to the current debate by suggesting that new evidence and new types of teacher training are urgently needed to help schools make informed decisions about phone use in schools.

Authors:

Senior Lecturer in Pedagogy in Sport, Physical Activity and Health, University of Birmingham

Pro-Vice-Chancellor (Education), University of Birmingham

Reader in Public Health & Epidemiology, University of Birmingham

Source: Smartphones are powerful personal pocket computers – should schools ban them?

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Critics:

The use of mobile phones in schools by students has become a controversial topic debated by students, parents, teachers and authorities. People who support the use of cell phones believe that these phones are essential for safety by allowing children to communicate with their parents and guardians, could simplify many school matters, and it is important in today’s world that children learn how to deal with new media properly as early as possible.

To prevent distractions caused by mobile phones, some schools have implemented policies that restrict students from using their phones during school hours. Some administrators have attempted cell phone jamming, but this practice is illegal in certain jurisdictions. The software can be used in order to monitor and restrict phone usage to reduce distractions and prevent unproductive use. However, these methods of regulation raise concerns about privacy violation and abuse of power.

Phone use in schools is not just an issue for students and teachers but also for other employees of educational institutions. According to the Governors Highway Safety Association, while no state bans all mobile phone use for all drivers, twenty states and the District of Columbia prohibit school bus drivers from using mobile phones.[38] School bus drivers have been fired or suspended for using their phones or text-messaging while driving.

Cellphone applications have been created to support the use of phones in school environments. As of February 2018, about 80,000 applications are available for teacher use. A variety of messaging apps provide communication for student-to-student relationships as well as teacher-to-student communication. Some popular apps for both students, teachers, and parents are Remind and ClassDojo. About 72% of top-selling education apps on iOS are for preschoolers and elementary school students. These apps offer many different services such as language translation, scheduled reminders and messages to parents.

See also

5 Questions to Ask Before Including Services in Your Bootstrapping Strategy

Most tech entrepreneurs these days stay away from services because investors are looking for high-margin, repeatable revenue. Service revenues don’t command the same multiples that product revenues do.

When I decided to bootstrap my startup, I never expected to be selling professional services. I quickly learned, however, that offering services tied to your product can be incredibly useful when bootstrapping. When my company started offering design and development services utilizing our low-code development platform, these services led to high-margin recurring revenue and greatly improved unit economics. These services also drove a tremendous amount of customer success.

But, service offerings are not for everyone. Here are a few questions you should ask yourself in order to determine whether services should be part of your bootstrapping efforts.

Related: 5 Reasons Bootstrapping Your Business is the Best Thing You Can Do

Do the services have good margins?

For bootstrapping to work, you need a healthy margin. At one of the companies I founded, our professional services were a necessary element of customer onboarding since product implementation was incredibly complex and not self-service.

Our professional services margin was -20%, which eroded our cash significantly. In this instance, service was not a revenue center but a loss leader — something we had to offer to secure the more valuable recurring revenue. If you find yourself in the same boat, services will never be a viable bootstrapping strategy. They could, however, be a tool you utilize to drive the rapid growth of recurring revenues.

Does the market/customer want the services?

Many products simply can’t be used by most people without a services component. At my company, we found that even though our low-code development platform could be utilized by people with minimal coding expertise, certain segments of our user base simply didn’t have the inclination to build their solution on our platform. We also discovered that even with powerful tools, many people wanted to leverage the expertise of an experienced software design team.

This prompted us to spin up a services team that could charge for design and development as an initial project and even provide ongoing development services on a monthly basis. Going this route is driving a three-to-six month payback on and marketing investment for us. Do these types of opportunities exist for you?

Related: 7 Ways to Bootstrap Your Business to Success

Can your service offering eventually be outsourced to an ecosystem of providers?

Services can serve as a bridge to help fund platform losses up to a point where outsiders can take over. Building an ecosystem can create an awesome flywheel effect, whereby participants not only become service providers but a channel for bringing in new product sales — without the expense of having to add to your own sales team.

Salesforce and Workday both did a brilliant job of executing this strategy. Ideally your product will gain enough acceptance that you can sell off your services division for additional profit.

Do services provide you with more customer intimacy and enhance your retention metrics?

A customer’s switching costs go way up when there is both a human and technological connection to your product and services. This sort of intimacy can provide a significant boost to your retention metrics and ensure predictable revenue.

Having great people to support clients can make up for early product deficiencies and create a level of trust that a pure low-touch product cannot. This is especially important in the early days of any startup’s product lifecycle.

Related: What Nobody Tells You About Taking VC Money

Can bootstrapping with services strengthen your product development?

Launching a services division also provides another benefit: the chance for you to “eat your own dogfood.” It’s a fact that when employees use their own product, it gets markedly better. At my company, we rotate core team members in and out of the professional services team to ensure every engineer feels what our customers feel. I believe this leads to product brilliance.

Now I’m not advocating you become a services company, but having a product company with a service business could stave off having to secure venture backing before your product is more mature. This can help you avoid things like dilution, a loss of control and the pressure to grow fast for a speedy exit.

As someone who’s previously founded two venture-backed startups, I like how bootstrapping with services is allowing my company to grow more thoughtfully. We have time to think about product/market fit before scaling up, we’re not pursuing growth rates that our platform can’t support, we’re making smart hires and we’re scrutinizing the ROI of all of our expenses because every dollar counts.

Additionally, we are vetting the utility of our own product with real-life customers and creating a virtuous circle of feedback to drive new features. I feel like it’s the smarter way to evolve a business like ours — building a company for the long haul versus hitting some arbitrary goal to secure additional venture capital.

There is one important consideration before bootstrapping with services: You’ll want to make sure you’re growing (albeit at a deliberate pace) and not just treading water. That’s why the above questions are something you’ll want to consider before following my lead. It’s critical you feel confident that you’ll create enough runway and customer success for your ultimate business model to take shape, while not letting services become a distraction.

By:

Source: 5 Questions to Ask Before Including Services in Your Bootstrapping Strategy

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Critics:

In computer technology the term bootstrapping, refers to language compilers that are able to be coded in the same language. (For example, a C compiler is now written in the C language. Once the basic compiler is written, improvements can be iteratively made, thus pulling the language up by its bootstraps) Also, booting usually refers to the process of loading the basic software into the memory of a computer after power-on or general reset, the kernel will load the operating system which will then take care of loading other device drivers and software as needed.

Bootstrapping can also refer to the development of successively more complex, faster programming environments. The simplest environment will be, perhaps, a very basic text editor (e.g., ed) and an assembler program. Using these tools, one can write a more complex text editor, and a simple compiler for a higher-level language and so on, until one can have a graphical IDE and an extremely high-level programming language.

Historically, bootstrapping also refers to an early technique for computer program development on new hardware. The technique described in this paragraph has been replaced by the use of a cross compiler executed by a pre-existing computer. Bootstrapping in program development began during the 1950s when each program was constructed on paper in decimal code or in binary code, bit by bit (1s and 0s), because there was no high-level computer language, no compiler, no assembler, and no linker.

A tiny assembler program was hand-coded for a new computer (for example the IBM 650) which converted a few instructions into binary or decimal code: A1. This simple assembler program was then rewritten in its just-defined assembly language but with extensions that would enable the use of some additional mnemonics for more complex operation codes.

The enhanced assembler’s source program was then assembled by its predecessor’s executable (A1) into binary or decimal code to give A2, and the cycle repeated (now with those enhancements available), until the entire instruction set was coded, branch addresses were automatically calculated, and other conveniences (such as conditional assembly, macros, optimisations, etc.) established. This was how the early assembly program SOAP (Symbolic Optimal Assembly Program) was developed. Compilers, linkers, loaders, and utilities were then coded in assembly language, further continuing the bootstrapping process of developing complex software systems by using simpler software.

See also