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
March 24, 2011
Journal of Taxation, Vol. 114, March 2011
Brooklyn Law School, Legal Studies Paper No. 225
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
Date posted: March 28, 2011