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

Journal of Taxation, Vol. 114, March 2011

Brooklyn Law School, Legal Studies Paper No. 225

14 Pages Posted: 28 Mar 2011  

Kelly E. Alton

Nationwide Exchange Services

Bradley T. Borden

Brooklyn Law School

Alan S. Lederman

Akerman, Senterfitt

Date Written: March 24, 2011

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.

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

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: https://ssrn.com/abstract=1794191

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

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