One of the most fascinating things about Section 1031 tax law is that relatively few cases have been resolved in court. Most of the opinions shaping the mechanics of Section 1031 exchanges, including PLR 9232030, come from non-authoritative sources, such as Revenue Procedures and Private Letter Rulings directly from the IRS. Documents from the IRS […]
Section 1031 is one of the most financially beneficial provisions in the tax code. This section literally allows taxpayers to use borrowed tax money to purchase more investment or business property. With this borrowed tax money, taxpayers can make their own wealth grow faster. Although this may not have been the original intent of Sec. […]
Although the 1031 industry is relatively new, going back just several decades, Section 1031 is nearly 100 years old. The 1031 industry has come about only because the Treasury Regulations have codified delayed exchanges and established the role of facilitators. Before these regulations, the contours of 1031 exchanges were still quite fuzzy. Repeatedly, courts stressed that the […]
Providing counsel on Sec. 1031 exchanges can be challenging for many reasons. One reason why this can be challenging is because there’s a lot of uncertainty regarding the contours of Sec. 1031 requirements. The parking arrangements in a reverse 1031 like kind exchange, for instance, gave rise to a veritable bevy of litigation. The Sec. […]
At its most basic level, a Sec. 1031 exchange is all about insulating taxpayers from receiving taxable gain from a sale. In addition to providing counsel, the function of a Sec. 1031 intermediary is to prevent the taxpayer from receiving sale proceeds. Intermediaries are therefore necessary in every type of 1031 transaction, except for direct swaps. If a […]
We’ve devoted several posts to debt terminology (i.e. debt resolution, debt consolidation, etc.). In this post, we’d like to follow this same style and discuss a few terms which you’ll find in advanced Sec. 1031 research. These are terms which you won’t usually find in the most straightforward 1031 exchanges. As we know, 1031 exchanges […]
In the past, we’ve touched on various issues related to state taxation of 1031 exchanges. For instance, in our post on New York State, we mentioned the requirements which pertain to state tax withholding, tax forms, and the layers of tax which can apply. We’ve also discussed the unique case of Pennsylvania. As you may recall, […]
As we’ve seen, the basic concept of a 1031 exchange is simple, but certain exchanges can present many complex issues. We’ve covered complex topics such as the partnership installment note method, leasehold exchanges and others. Part of the reason for the complexity is the lack of clear authority. The IRS has issued documents of their […]
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