Statutory Limitations on Like-Kind ExchangesThe proposed regulations provide guidance implementing changes enacted in the Tax Cuts and Jobs Act (TCJA). These proposed regulations amend the existing regulations adding a definition of real property reflecting statutory changes limiting section 1031 to exchanges of real property. The proposed regulations provide a rule addressing a taxpayer’s receipt of personal property that is incidental to real property. They also affect taxpayers that exchange business or investment property for other business or investment property in determining whether the exchanged properties are real property for Section 1031 purposes. Read More » |
|
|
|
|
Call Us
Intent to Hold for Investment: 12-Year Holding Period
Intent To Hold For Investment: 12-Year Holding Period Lessons From Allen v. United States Is a 12-year holding period long enough for property to be considered to be “held for investment?" At first blush, a [...]
Two 1031 Audits: Cash Boot at Closing/Failed Exchange & ID Violation
California FTB Denies Exchange Based on Cash Out at Closing: Analysis and Response It’s no secret that the California Franchise Tax Board (“FTB”) has become very aggressive in challenging 1031 exchanges. In a recent audit, [...]
Taxpayer Uses Disqualified Person as a QI
Taxpayer Uses Disqualified Person as a Qualified Intermediary (QI) In Blangiardo v. Commissioner, T.C. Memo. 2014-110, the taxpayer hired his son to serve as his intermediary. The taxpayer duly reinvested the exchange proceeds into like-kind replacement [...]
1031 Exchanges Face Uncertain Future
1031 Exchanges Face Uncertain Future Section 1031 Under Siege There are currently three different proposals that the federal government is weighing, which would significantly alter Section 1031: Former Sen. Max Baucus (D-Montana), who became U.S. [...]