Do Serial Exchangers Get Cash, with Extra Time to Boot, Under New Letter Ruling?

Alton, Kelly; Borden, Bradley; Lederman, Alan

Abstract

Download This Paper | Share | Email |Add to Briefcase

Do Serial Exchangers Get Cash, with Extra Time to Boot, Under New Letter Ruling?

Akerman, Senterfitt

March 24, 2011

Journal of Taxation, Vol. 114, March 2011
Brooklyn Law School, Legal Studies Paper No. 225

Abstract:
Related-party exchanges raise the issue of improper extension of the Section 1031(a)(3) 45-day identification and 180-day exchange periods. Related-party exchanges also call into question the amount of boot a related party may receive without triggering an abusive cash-out. A recent letter ruling involving two sequential related-party Section 1031 exchanges makes these issues doubly evident.

Number of Pages in PDF File: 14

Keywords: like-kind exchange, related-party exchange, section 1031

Accepted Paper Series

Download This Paper

Date posted: March 28, 2011

Suggested Citation

Alton, Kelly E., Borden, Bradley T. and Lederman, Alan S., Do Serial Exchangers Get Cash, with Extra Time to Boot, Under New Letter Ruling? (March 24, 2011). Journal of Taxation, Vol. 114, March 2011; Brooklyn Law School, Legal Studies Paper No. 225. Available at SSRN: http://ssrn.com/abstract=1794191

Contact Information

Kelly E. Alton Nationwide Exchange Services ( email ) 50 West San Fernando Street Suite 300 San Jose, CA 95113 United States
Bradley T. Borden (Contact Author) Brooklyn Law School ( email ) 250 Joralemon Street Brooklyn, NY 11201 United States
Alan S. Lederman Akerman, Senterfitt ( email ) One Southeast Third Avenue 25th Floor Miami, FL 33131-1714 United States

Abstract

Do Serial Exchangers Get Cash, with Extra Time to Boot, Under New Letter Ruling?

Kelly E. Alton

Bradley T. Borden

Alan S. Lederman

Date posted: March 28, 2011

Suggested Citation

Contact Information

Kelly E. Alton

Bradley T. Borden (Contact Author)

Alan S. Lederman