Financing Reverse Exchanges and Safeguarding Exchange Proceeds
Bradley T. Borden
Brooklyn Law School
Journal of Taxation and Regulation of Financial Institutions, Vol. 22, No. 1, 2008
Over the last several years, reverse exchanges have become a fixture of section 1031. A fluid economy and a strained financial industry send a reminder that safe guarding exchange proceeds in reverse exchanges is paramount. This Article reviews reverse exchange structures, both safe harbor and non-safe harbor, and describes how such transactions must be financed to satisfy tax law requirements and safe guard exchange proceeds. The Article is adapted, with permission, from Chapter 5 of Tax-Free Like-Kind Exchanges.
Number of Pages in PDF File: 21
Keywords: reverse exchange, section 1031, title-parking exchange, exchange proceeds, qualified intermediary, exchange accommodation titleholder
JEL Classification: A10, D31, D63, E62, H23, H24, H25, K34Accepted Paper Series
Date posted: November 1, 2008
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