What is a single exchange?

Article Abstract:

The designation of a single exchange is an important consideration when exchanging multiple properties. Three replacement properties can be designated for each separate exchange, but taxpayers should structure exchange transactions clearly enough to withstand court scrutiny. In determining whether a transaction will be called a single exchange, factors to consider include buyer's identity, properties' proximity to each other, common advertising, the use of a single escrow, escrow agent, intermediary, and broker, and so on.

Security and commodity exchanges, Miscellaneous Intermediation, Exchanges ex Securities & Commodities, Exchanges, Commodity exchanges

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Tax-free real estate transactions taxing ghosts under section 1031

Article Abstract:

This article concerns IRS Letter Ruling 9911033 where the IRS ruled that a direct acquisition of replacement property was effectuated under IRC tax-free exchange section 1031(a)(3) in an real property exchange involving a grantor trust and a limited liability company. The IRS seems to have confused the underlying pass-through entity issue, but its apparent conclusion is likely correct.

United States, Tax Law, Public Finance Activities, Tax planning, Tax-free exchanges

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Combined exchanges and installment sales

Article Abstract:

The IRS has issued proposed regulations for taxation of combined installment sales and deferred like-kind exchanges of property. The rules are favorable to taxpayers but they do not encourage new tax planning strategies. This is due to a first allocation of basis to nonrecognition property and a first allocation of gain to recognition property.

Real property tax, Real property taxes, Installment land contracts

Similar abstracts:

• Abstracts: Allocation of value between real estate and intangible assets. Solving corporate real estate problems
• Abstracts: Underwater property and basis limitations. Recent rulings stake out the Service's position on section 1031. Section 704(c) - proposed regulations relating to property contributed to a partnership

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