Issues in cashing out of an exchange

Article Abstract:

The author discusses tax issues in attempting to cash out deferred exchanges prior to the 180-day limitation period.

United States, Safe harbor (Taxation)

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St. Laurent: is there still a role for an exchange intermediary?

Article Abstract:

The Tax Court's 1996 St. Laurent decision on deferred exchanges is flawed and will be of little benefit to most taxpayers. The decision contradicts the accepted three-replacement-property rule on exchanges and appears to depart from the traditional use of intermediaries in such transactions. Using questionable reasoning, the court rejected the IRS's arguments that the taxpayer failed to properly designate the exchange properties. The court's interpretation of IRC s. 1031 exchange requirements is similarly suspect.

Cases, Tax-free exchanges

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How do you do an exchange with a special purpose entity?

Article Abstract:

Real property owners attempting like-kind exchanges can face problems when lenders require replacement properties to be held by special purpose entities. Since these entities are considered bankruptcy remote, lenders increasingly are requiring them to protect their loans. Possible alternatives includes the use of a limited partner, limited liability company, or business trust to satisfy lender requirements.

Loans

Similar abstracts:

• Abstracts: Increasing the residential gain exclusion with undivided and future interests. Combining the residential gain exclusion with a tax-free exchange

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