Journal of Taxation, Vol. 111, p. 324, December 2009
25 Pages Posted: 22 Dec 2009
Date Written: 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.
Keywords: related-party like-kind exchange, Teruya Brothers
Suggested Citation: Suggested Citation
Alton, Kelly E. and Borden, Bradley T. and Lederman, Alan S., Related Party Like-Kind Exchanges: Teruya Brothers and Beyond (December 2009). Journal of Taxation, Vol. 111, p. 324, December 2009. Available at SSRN: https://ssrn.com/abstract=1526689