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
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