Business Services Industry
IRS safe harbor on reverse like-kind exchanges.
Kiplinger Tax Letter, The, December, 2000
An IRS safe harbor on reverse like-kind exchanges is drawing flak. These are tax-deferred swaps where the seller acquires replacement realty before selling the original property...the opposite of a traditional swap. The Service will OK reverse exchanges if title to replacement real estate is held by an unrelated third-party intermediary until deal is completed.
Dispute involves the 180-day test...sale of the original property must occur within 180 days after intermediary receives replacement realty.
Tax experts want a two-year period...think 180 days is too short.
IRS isn't likely to allow any more time, key officials tell us.
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