Download - IRC Section 1031 Tax-Deferred Exchanges · Tax-Deferred Exchanges IRC Section 1031 Section 1031 has been part of the Internal Revenue Code since 1921. The language of the Code has

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IRC Section 1031

Tax-Deferred Exchanges

IRC Section 1031

Section 1031 has been part of the Internal Revenue Code since 1921.

The language of the Code has been modified very little since 1921, but significant regulatory guidance has made these transactions accessible to all taxpayers.

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Starker and The 1984 Tax Reform Act

In the mid-1970s, the Starker cases set the stage for the non-simultaneous exchange.

In 1984, the Tax Reform Act formally sanctioned the delay between the disposition of relinquished property and the acquisition of replacement property.

The 1984 Tax Reform Act also imposed the 45-day Identification Period and the 180-day Exchange Period.

Three General Statutory Requirements

Properties Must be Held for Business or Investment Use

Properties Must Be Like-Kind to Each Other

The Transaction Must be Structured as an Exchange of One Property for Another

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Property Held for Investment or Business Use

Property must be held for investment or for use in a trade or business in which Taxpayer is engaged.

How long must the Taxpayer own the property prior to the exchange?

Intent is key to this inquiry.

Look at facts and circumstances.

Consider individual risk tolerance.

Consider Taxpayer’s behavior.


Taxpayer sells relinquished property in August 2015and structures a tax-deferred exchange.

Taxpayer acquires replacement property in November 2015.

In January 2016, Taxpayer receives, and accepts, an offer to sell his newly acquired replacement property to the owner of adjacent property.

Can Taxpayer structure the sale as an exchange?

Has Taxpayer held the replacement property for investment?

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PLR 8429039 – two years of business or investment use is sufficient to meet the requirement under IRC Section 1031 that the property was held for the requisite intent.

Neal T. Baker Enterprises, Inc. v. Commissioner (1998) –Taxpayer attempts to exchange vacant land after owning it for 11 years. Taxpayer is deemed to have held the land “for sale” during the entire holding period.

Like-Kind Standard

Property classified as realty under state law is “like-kind”.

“Like-Kind” refers to the nature or the character of the property, not its grade or quality.

Unimproved property is like-kind to improved property.

The property need not be income producing.

Personal property must be exchanged for property that is of a like class.

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The Exchange Requirement

The Exchange must be

structured as a reciprocal

transfer of one property for

another as distinguished

from a sale followed by a

re-investment.

Taxpayer may not actually

or constructively receive the

proceeds of sale.

The Exchange Requirement

Crandall & Dulin v. Commissioner T.C. Summary Opinion, February 2011 – Taxpayers failed to include any exchange language in their documents and had constructive receipt of their sale proceeds.

Peter T. Morton v. United States of America - April 2011 – Taxpayer exchanged a G-IV aircraft for a G-V. Contrary to Taxpayer’s instruction the closing company wired sale proceeds to Taxpayer’s account. The error was quickly rectified, and Taxpayer successfully argued that his intention was very clearly documented and he should not be penalized for the error of the closer.

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Forward Exchange Mechanics

Prior to Closing on the Sale of Relinquished Property:

Taxpayer executes a series of documents evidencing their intent to exchange the property.

At closing, net sale proceeds are wired into the qualified trust account.


STEP 1: Sale of Relinquished Property

Taxpayer

QI

Assignment of Contract Notice to Purchaser

Relinquished Property Proceeds

Purchaser

Title to Relinquished Property

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What makes the account a “qualified” account?

Taxpayer’s rights to receive, pledge, borrow, or otherwise obtain the benefits of the cash held in the account must be limited to those specific exceptions described in Treasury Reg. 1.1031(k)-1(g)(6).


The Qualified Intermediary “Acquires and Transfers” both properties in the exchange.

TAM 200130001 – failure to comply with the specific provisions of the safe harbor requirement that the QI “acquires and transfers” the property results in the disqualification of an exchange.

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STEP 2: Identification of Replacement Property

Taxpayer

QI

The Identification Notice must be made in a written document that is signed by the Taxpayer and hand delivered, mailed, telecopied or otherwise sent before the end of the Identification Period.

Identification Options

The Taxpayer can choose any one of the three rules when identifying replacement property:

Three-Property Rule - Three properties of any fair market value;

200% Rule - Any number of properties as long as their aggregate FMV as of the end of the Identification Period does not exceed 200% of the aggregate FMV of all relinquished properties;

95% Rule - If the Taxpayer fails to comply with the three-property and 200% identification rules, its identification will be considered valid and any replacement property which is identified within 45 days and received within 180 days will qualify; provided the Taxpayer receives at least 95% of the value of all of the identified properties before the end of the Exchange Period.

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Taxpayer sells relinquished property for $5 million and identifies the following properties:

1. 135 S. LaSalle Street, Chicago

2. The Chrysler Building

3. NW corner of Main and 12th, Walnut Creek, CA

Identification Issues

1. 135 S. LaSalle Street, Chicago, IL

Property may be described by Street Address, City & State

2. The Chrysler Building

Property may be described by “distinguishable name”

3. NW corner of Main & 12th, Walnut Creek, CA

Property must be “unambiguously described”.


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1. 135 S. LaSalle Street, Chicago, IL

Property may be described by Street Address, City & State

If Taxpayer sells Relinquished Property for $5 million, is it Taxpayer’s intention to acquire 100% of the building located at 135 S. LaSalle Street, Chicago, IL.

If Taxpayer intends to acquire a tenancy-in-common interest in the Replacement Property is it sufficient to identify the entire property?


Taxpayer sells relinquished property on February, 2012.

Taxpayer’s 45th day falls on a Saturday, March 17, 2012.

On Monday, March 19, Taxpayer sends an Identification form to its QI with the date of March 17.

The QI acknowledges receipt of the Identification form as of March 19, but Taxpayer changes the date to March 17.

Dobrich v. Commissioner, T.C. Memo 1997-477

The Tax Court found clear and convincing evidence of Taxpayer’s intent to defraud the government by submitting false documents in order to evade taxes believed to be owing.


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STEP 3: Acquisition of Replacement Property

Taxpayer Assignment of ContractNotice to Seller

QI

Seller

ReplacementProperty is deeded directly from the Seller to the Taxpayer

Cash held by the QI is paid directly to the Seller or into a closing escrow.

Boot Netting RulesWhat is “Boot”?

Boot is other property or money received in an exchange that is not like kind to the property given up.

The term originated (purportedly) in the days of horse trading – take the horse and get the boots too.

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Boot Netting RulesHow to Recognize and Avoid Boot

The rules regarding the effect of receiving boot are found in the Treasury Regulations at 1.1031(b)-1.

The gain, if any, shall not exceed the fair market value of the money or other property received.

The loss, if any, shall not be recognized under Section 1031 to any extent.

Boot Netting Rules

General Rules to Avoid Boot

Trade even or up in value;

AND

Reinvest all of your equity into replacement property.

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Boot Netting Rules


Cash paid to acquire replacement property offsets cash received on the sale of relinquished property:

Relinquished Property

FMV: $100

Debt: $ 0

Equity: $100

Replacement Property

FMV: $100

Debt: $ 0

Equity: $100

No boot received.

Boot Netting Rules


Cash paid to acquire replacement property offsets debt reliefon the sale of relinquished property:


FMV: $100

Debt: $ 50

Equity: $ 50


FMV: $100

Debt: $ 0

Equity: $100

Taxpayer is relieved of $50 of debt. That debt relief is considered consideration that is “other property or money” that can cause gain recognition.

Replacement Property is acquired with all cash. The $50 of new cash offsets the debt relief.

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Boot Netting Rules


Debt assumed on the acquisition of Replacement Property offsets debt relief on the transfer of Relinquished Property.


FMV: $100

Debt: $ 50

Equity: $ 50


FMV: $100

Debt: $ 50

Equity: $ 50

Taxpayer is relieved of $50 of debt. That debt relief is considered consideration that is “other property or money” that can cause gain recognition.

Replacement Property is acquired with $50 of new debt and $50 of equity. No gain is recognized.

Boot Netting Rules


Debt assumed on the acquisition of Replacement Property will not offset cash received on the transfer of Relinquished Property.


FMV: $100

Debt: $ 50

Equity: $ 50


FMV: $100

Debt: $ 80

Equity: $ 20

Unspent Cash: $ 30

Taxpayer secures a mortgage of $80. As a result, not all of the equity from the relinquished property sale is re-invested.

Taxpayer has boot of $30 and must recognize gain on that amount.

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Reverse Exchanges

Revenue Procedure 2000-37

A Safe Harbor for “Parking Arrangements”

This Rev. Proc. provides a safe harbor under which the IRS will not challenge the qualification of relinquished property or replacement property in certain “reverse exchanges.”

Parking Arrangement Conditions

Indicia of Ownership must be transferred to the “Exchange Accommodation Titleholder” (EAT).

EAT can acquire either the Relinquished Property (exchange first) or the Replacement Property (exchange last).

All parties must treat the EAT as the beneficial owner of the parked property for Federal Income Tax purposes.

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Parking Arrangement Conditions

Taxpayer must identify the Relinquished Property within 45 days from the date the EAT acquires the parked replacement property.

Combined period the property is held in the parking arrangement cannot exceed 180 days.

Permissible Agreements

EAT can also act as QI.

Taxpayer can guarantee or co-sign on any loan documents or debt instruments the EAT takes on to acquire the parked property.

Taxpayer can loan funds directly to the EAT at no interest.

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Permissible Agreements

EAT can lease the parked property to the Taxpayer at no rent.

Taxpayer can manage the property, and oversee construction of improvements on the property.

The Accommodation Agreement can include put and call provisions as well as formula pricing to account for any gain or loss that occurs while the EAT owns the property.

Replacement Property Parking

Acquisition of Replacement Property by EAT

Title to

Replacement PropertySeller

E A T

Taxpayer

Net Lease

Lender

Loan AgreementPromissory NoteOther SecurityInstruments

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Identification of Relinquished Property

E A T

Taxpayer

The Identification Notice must be made in a written document that is signed by the Taxpayer and hand delivered, mailed, telecopied or otherwise sent before the end of the Identification Period.

Identification



Sale of Relinquished Property

Taxpayer

QI

Assignment of Contract Notice to Purchaser

Relinquished Property Proceeds

Purchaser

Title to Relinquished Property

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Transfer of Replacement Property from EAT

Close out of Reverse Exchange

2. Payment of Purchase Price

1. Assignment of Contract

1. Taxpayer Assigns its rights under the contract for purchase of the Replacement Property to the QI.

2. Taxpayer then instructs the QI to pay the purchase price to the EAT as Seller of the Replacement Property


QI

E A T

Taxpayer

Transfer of Replacement Property from EAT

Close out of Reverse Exchange

3. EAT uses the proceeds from the Relinquished Property sale to pay down (or pay off) the debt.

4. EAT then transfers the replacement property to the Taxpayer by Assignment of LLC interests.


QI

E A T

Taxpayer

Lender

3. Payoff or pay down senior loan

4. Assignment of LLC Interests

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Exchange Last Parking ArrangementPractical Considerations:

1. Will a third-party lender be comfortable with the EAT as the borrower & titleholder?

* A third party lender should be comfortable that the EAT is acquiring the property as the Taxpayer’s agent.

* The Taxpayer may co-sign the loan documents & guarantee the loan if required.

* The loan documents can restrict the transfer of the property (or the LLC interests) to a single “Permitted Transferee” i.e. the Taxpayer.

* If the Replacement Property is ultimately transferred via an Assignment of LLC Interests, the loan documents will not need to be modified.

Exchange Last Parking Arrangement

Practical Considerations:

2. How do you coordinate document execution?

* The Taxpayer (or officers of the Taxpayer entity) can be named officers of the titleholding LLC to facilitate document signing.

* The Taxpayer may be named as the Manager or the Special Member of the titleholding LLC to facilitate document signing.

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3. Will transfer taxes be assessed twice – once when the EAT acquires the property from the Seller and again when the EAT transfers the property to the Taxpayer?

* PLR 200148042 [Chicago Deferred Exchange Company’s Ruling]: Taxpayer and EAT can declare that the EAT is acting as the Taxpayer’s agent for all purposes except for Federal income tax purposes.

* A transfer between an agent and its principal may be an exempt transfer and not subject to local transfer tax.

* Look into the incidental costs of a parking arrangement.



4. Can improvements be made to the Replacement Property while it’s parked with the EAT?

* The Rev. Proc. specifically permits the Taxpayer to oversee construction of any improvements during the parking period.

* The Taxpayer may act as construction manager of the property.

* The EAT authorizes draw requests that are approved by the Taxpayer.

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5. Who interfaces with the tenants at the property?

* During the parking period, the EAT typically net leases the property to the Taxpayer so the Taxpayer deals directly with tenants.

* The rent amount under the lease is set equal to any monthly debt service so the income/expense is a wash to the EAT.

* The net effect is that the Taxpayer benefits from the economics of the property and deals with the day to day operations.

Recent Guidance

PLR 201242003 – Related Parties Sign Separate Accommodation Agreements for Same Replacement Property

Taxpayer is a REIT Operating Limited Partnership

Affiliate is a Qualified REIT Subsidiary

Taxpayer and Affiliate both own one or more multifamily residential apartment properties.

Taxpayer and Affiliate both targeted a specific property for acquisition as Replacement Property for separately structured like-kind exchanges.

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Recent Guidance


Replacement Property Closing Date preceded the date on which either Taxpayer or Affiliate could transfer Relinquished Property in a forward delayed exchange.

Taxpayer and Affiliate both entered into a Qualified Exchange Accommodation Agreement (QEAA) with an Exchange Accommodation Titleholder (EAT).

Recent Guidance


Taxpayer’s QEAA acknowledges that EAT had entered into a concurrent agreement with Affiliate, giving Affiliate the right to acquire the Replacement Property (in whole or in part).

Taxpayer’s rights to acquire Replacement Property are subject to Taxpayer giving written notice to EAT of its intention to complete the acquisition.

Taxpayer’s rights to acquire Replacement Property terminate upon EAT’s receipt of written notice from Affiliate of Affiliate’s intention to complete the acquisition.

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Recent Guidance

PLR 201242003 – Related Parties Sign Separate Accommodation Agreements for Same Replacement Property – October 19, 2012

On Day 45 Taxpayer identified 3 potential Relinquished Properties.

On Day 45 Affiliate identified 1 potential Relinquished Property.

Prior to day 180, Taxpayer sold Relinquished Property through a Qualified Intermediary and acquired Replacement Property from the EAT.

Recent Guidance


The ruling concludes that Rev. Proc. 2000-37 allows a Taxpayer to complete a reverse exchange without concern that the EAT’s ownership of the property will be attributed to Taxpayer.

EAT may enter into QEAAs with more than one entity, including related parties to Taxpayer, all of whom have a bona fide intent to acquire the property as Replacement Property for their respective exchanges.

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IRC Section 1031(a)(2)(D): prohibits the exchange of interests in a partnership.

Manny, Moe & Jack own investment property in Chicago.

Title is vested in the MJM, LLC and each year Manny, Moe & Jack receive K-1s from their tax preparer showing their respective shares of income and deductions.

In early January, MJM, LLC signs a contract to sell their investment property to ACME Corporation.

Partnership Exchanges

Manny and Moe are interested in exchanging their interests in the property in a tax-efficient manner.

Jack intends to take his cash and stuff it in a shoe box.

What are their options?


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• Drop and Swap

Dissolve the partnership and distribute tenancy in common interests prior to closing.

• Swap and Drop

The Partnership acquires replacement and later cashes Jack out.

• Partial Installment Sale

Cash out partner receives an installment note at the relinquished property closing in redemption of his interest.


MJM, LLC

Jack Manny Moe

Sale for Cash Exchange Exchange

Dissolving the Partnership: “Drop & Swap”

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Transfer from partnership to individual co-owners should be done in advance of closing.

The partners should act as co-tenants.

Contrast Chase v. Commissioner where taxpayer received an undivided 46% interest in property previously held by partnership.

The deed from partnership to Chase was never recorded, all income and expenses were paid into the partnership account.


Rev. Ruling 75-292 and Rev. Rul 77-337:

The IRS ruled the “held for” requirement under Section 1031 could not be attributed to another entity through a non-recognition transaction.

The IRS has argued, and lost, the “held for” issue in several cases including: Magneson, Bolker and Maloney.


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Post-Exchange Partnership Dissolution: “Swap and Drop”

MJM, LLC

3rd Party Purchaser

Q.I.Relinquished

Property

CashMJM, LLC sells

relinquished property to Purchaser: funds are

directed to the Qualified Intermediary


MJM, LLC

Q.I.

3rd Party Seller


CashMJM, LLC acquires

replacement property from Seller: funds are

wired from the Qualified Intermediary

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MJM, LLC

Moe JackManny

At some date after closing, the MJM, LLC distributes tenancy in common interests in the property to the individual partners.

In Maloney v. Commissioner, Taxpayer corporation acquired replacement property them immediately liquidated and distributed property to the shareholders.

The Service argued that Maloney did not continue to hold the property for investment.

The Tax Court held that the dissolution was a continuation of an economic interest in the same investment.


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California State Board of Equalization Formal Opinion Under Revenue and Taxation Code Section 40

In the Matter of the Consolidated Appeals of RagoDevelopment Corporation et al.

Rago sold two investment properties in May 2003 and acquired a tenancy-in common interest in a shopping center in California in Jun 2003.

Pursuant to terms of the financing for the acquisition the co-tenants were obligated to transfer the property to a single purpose entity in January 2004.



The California FTB audited the transaction an disallowed it on the grounds that Taxpayers violated the requirement that the replacement property be held for investment.

The FTB argues that the transfer of the property to the LLC resulted in Taxpayer’s failure to meet the holding requirement for IRC Section 1031.


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Taxpayer’s counsel successfully argued that the transfer from Taxpayer to the new SPE did not change the Taxpayer’s underlying economic interest in the property and that Taxpayer’s intent did not change by virtue of the transfer.


Partial Installment Sale

At Relinquished Property closing, the Partnership takes a note from the Purchaser payable to the Partnership.

In redemption of Jack’s interest, the Partnership endorses the note to Jack.

Partnership acquires replacement property without Jack.

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Parking Arrangements and Foreclosure Situations

Taxpayer wants to acquire property out of foreclosure at auction in a reverse exchange using Rev. Proc. 2000-37.

• Taxpayer needs to have cash to attend the auction.

• The Exchange Accommodation Titleholder will be the grantee if the Taxpayer is the successful bidder.

• The auction house needs to agree to transfer the property to an entity that is owned by the EAT.

• If the balance of the purchase price for the property is financed, the lender needs to understand the EAT’s role.

• When does tax ownership transfer?

What does “held for investment or for productive use in a trade or business” mean in

the context of an IRC Section 1031 tax-deferred exchange?

Held for Investment Requirement under IRC Section 1031

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Effective for exchanges occurring after March 9, 2008, this Rev. Proc. provides a safe harbor for Taxpayers who sell “dwelling units” that are held for the production of income and used for personal purposes.



1. The dwelling unit is real property that is improved with an apartment, condominium or other living space that includes a sleeping area, kitchen and bathroom.

2. The dwelling unit is owned by the Taxpayer for at least 24 months prior to the exchange.

3. In each of the two 12-month periods prior to the exchange, the dwelling unit is used for personal purposes the greater of 14 days or 10% of the number of days the dwelling unit is rented.

4. In each of the two 12-month periods prior to the exchange, the dwelling unit is rented at a fair rental value for 14 days or more.


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Recent Tax Court Cases – Property Held for Personal Use

Yates v. Commissioner – T.C. Memo 2013-28

Taxpayer’s exchange was disallowed when Taxpayer moved into the replacement property 4 days after acquiring the property.



Yates v. Commissioner – T.C. Memo 2013-28

Taxpayer tried to claim the property was held for investment by pointing to language in the Purchase and Sale Agreement that requested the Seller of the property apply to the local town board to allow the property be used as a bed and breakfast (at buyer’s expense).

No such application was made and the Tax Court concurred that occupying the property as a principal residence precluded the Taxpayer from claiming the property was held for investment.


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Adams v. Commissioner – T.C. Memo 2013-7

Taxpayer exchanged a rental property for a single family home in Eureka, California which he rented to his son.

The son made the home livable (after dealing with mold, squatters and BEARS!) and maintained the home while he and his family resided there. The son paid rent that was a couple hundred dollars below the going rental rate.



Adams v. Commissioner – T.C. Memo 2013-7

The IRS disallowed the exchange on the ground that Adams acquired the Eureka, CA property for personal purposes –specifically to allow his son to live in the home at below-market rent.

The Tax Court held differently – that the Eureka, CA property was in fact held for investment and that the rent paid by Taxpayer’s son was appropriate given the level of rehabilitation and upkeep the son provided to the property without charge.


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Patrick A. Reesink v. Commissioner, T.C. Memo 2012-18

Taxpayer and his brother owned an apartment complex in San Francisco. After many years of turmoil – including Taxpayer accusing his brother of stealing from him, trying to strangle him, and poisoning his drinking water with cleaning fluid, Taxpayer filed for partition of the property.

The partition suit was settled and the property was sold. Taxpayer exchanged his tenancy in common interest in the San Francisco property for a single family rental home in Guernville, California.




Taxpayer attempted to rent the property and posted flyers around the neighborhood advertising the home for rent.

He interviewed several prospective tenants but none were interested in paying the $3,000/month rent Taxpayer was requesting.

Eight months after acquiring the replacement property, Taxpayer sold his primary residence and moved into the Guernville property.


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The IRS disallowed the exchange on the grounds that the Guernville property was not held for investment as evidenced by the fact that Taxpayer occupied the property as his primary residence a few months after acquiring the property.

The Tax Court disagreed and concluded that Taxpayer’s actions evidenced his intention to hold the property for investment notwithstanding the fact that the property was never rented.

The exchange was upheld.



Goolsby v. Commissioner, T.C. Memo 2010-64

Taxpayer entered into a contract to acquire a single family home in GA (Pebble Beach).

The acquisition was conditioned on the sale of Taxpayer’s primary residence.

Taxpayer later signed a contract to sell investment property he owned in California. When the investment property sold, Taxpayer entered into a tax-deferred exchange.

FEA 2013 Regional Meeting


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Shortly after the sale of the investment property, Taxpayer sold his primary residence and moved in with his in-laws.

To complete his exchange, Taxpayer acquired:

1. the Pebble Beach property; and

2. a four-unit residential property.




Taxpayer attempted to rent out the Pebble Beach property by posting an ad in the local neighborhood circular.

At no time did Taxpayer check the homeowners association manual to see if the home could be rented.

After two months with no renter, Taxpayer and his wife moved into the Pebble Beach property.



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The Tax Court held the Pebble Beach property was not held or investment based on the following factors:

1. Taxpayer moved into the property two months after acquiring the property.

2. Taxpayer’s purchase of the Pebble Beach property was contingent on Taxpayer’s sale of his primary residence.




The Tax Court held the Pebble Beach property was not held or investment based on the following factors:

3. Taxpayer interactions with their Qualified Intermediary revealed their lack of investment intent.

4. Taxpayer failed to research whether the property could be rented under the Homeowner Association Rules.


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Barry E. Moore v. Commissioner, T.C. Memo 2007-134

Taxpayer sold a vacation home and acquired a new vacation home in a transaction he reported as a tax-deferred exchange under IRC Section 1031.

The transaction was disallowed on the grounds that the properties were not held for investment, but for personal use.

Taxpayer argued that their investment intent was evidenced by their hope that the properties would appreciate in value resulting in a profit when sold.





The Tax Court also cited the following factors:

1. Taxpayer used the property two weekends a month during the months of March – September for recreational activities.

2. Taxpayer took a home mortgage interest deduction for the properties, not investment interest.


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The Tax Court also cited the following factors:

3. Taxpayer did not depreciate the properties.

4. The mere hope that the properties would appreciate in value does not establish investment intent if the Taxpayer uses the property as a residence.


Property Held for Sale – Dealer Property

IRC Section 1221(a)(1) defines a capital asset as excluding any property held by a Taxpayer for sale to customers in the ordinary course of his trade or business.

Gain or loss on property held for sale by a dealer is generally treated as ordinary income for tax purposes.


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Neal T. Baker Enterprises, Inc. v. Commissioner T.C. Memo 1998-302

Taxpayer was both an investor and a developer in real estate.

Taxpayer sold 48 vacant lots that it owned for 11 years.

The IRS and the Tax Court concluded the properties were “held for sale” for the entire period Taxpayer owned the properties and the exchange was invalid.




The Court concluded the following:

1. Taxpayer was an active sub-divider and developer of real estate and had the burden of proving that when it was dealing with the exchange property that it was wearing the hat of a real estate investor;

2. Taxpayer’s accountants classified the exchange property as “work in progress” or “construction in progress” property and never moved the property to a “land” account.


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The Court concluded the following:

3. Taxpayer’s activities relative to the lots indicated his intent to develop and sell the properties.

4. Taxpayer’s principal business activity on its tax returns was “real estate subdivider & developer”.


IRC Section 1031 – Other ApplicationsIRC Section 1031 applies to any asset held for investment

or for productive use in a trade or business.

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Call us if you have questions:

Chicago Deferred Exchange Company

135 S. LaSalle Street, Suite 1940

Chicago, Illinois 60603

Phone: 312-580-9640

Toll free: 866-677-1031

Chicago Deferred Exchange Company

Download - IRC Section 1031 Tax-Deferred Exchanges · Tax-Deferred Exchanges IRC Section 1031 Section 1031 has been part of the Internal Revenue Code since 1921. The language of the Code has

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