Abstract

http://ssrn.com/abstract=1794191
 


 



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


Kelly E. Alton


Nationwide Exchange Services

Bradley T. Borden


Brooklyn Law School

Alan S. Lederman


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. and 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
Feedback to SSRN


Paper statistics
Abstract Views: 1,528
Downloads: 95
Download Rank: 165,276

© 2014 Social Science Electronic Publishing, Inc. All Rights Reserved.  FAQ   Terms of Use   Privacy Policy   Copyright   Contact Us
This page was processed by apollo6 in 0.907 seconds