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Full-Text Articles in Tax Law
Related Party Like-Kind Exchanges: Teruya Brothers And Beyond, Bradley T. Borden, Kelly E. Alton, Alan S. Lederman
Related Party Like-Kind Exchanges: Teruya Brothers And Beyond, Bradley T. Borden, Kelly E. Alton, Alan S. Lederman
Bradley T. Borden
The Ninth Circuit recently held that the non-tax-avoidance exception of Section 1031(f) generally will be unavailable where the taxpayer defers tax through a related-party exchange and cannot establish that the related party will incur a higher "tax price." This article examines this new addition to the body of law governing related-party exchanges and discusses planning approaches that exist after the ruling.