Do Serial Exchangers Get Cash, with Extra Time to Boot, Under New Letter Ruling?
Journal of Taxation, Vol. 114, March 2011
14 Pages Posted: 28 Mar 2011
Date Written: March 24, 2011
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.
Keywords: like-kind exchange, related-party exchange, section 1031
Suggested Citation: Suggested Citation