Related Party Like-Kind Exchanges: Teruya Brothers and Beyond
Kelly E. Alton
Nationwide Exchange Services
Bradley T. Borden
Brooklyn Law School
Alan S. Lederman
Journal of Taxation, Vol. 111, p. 324, December 2009
The Ninth Circuit recently held that the non-tax-avoidance exception of Section 1031(f) generally will be unavailable where the taxpayer defers tax through a related-party exchange and cannot establish that the related party will incur a higher "tax price." This article examines this new addition to the body of law governing related-party exchanges and discusses planning approaches that exist after the ruling.
Number of Pages in PDF File: 25
Keywords: related-party like-kind exchange, Teruya BrothersAccepted Paper Series
Date posted: December 22, 2009
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