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Do Serial Exchangers Get Cash, With Extra Boot, Under New Letter Ruling?, Bradley T. Borden, Kelly E. Alton, Alan S. Lederman
Do Serial Exchangers Get Cash, With Extra Boot, Under New Letter Ruling?, Bradley T. Borden, Kelly E. Alton, Alan S. Lederman
Bradley T. Borden
Related-party exchanges raise the issue of improper extension of the Section 1031(a)(3) 45-day identification and 180-day exchange periods. Related-party exchanges also call into question the amount of boot a related party may receive without triggering an abusive cash-out. A recent letter ruling involving two sequential related-party Section 1031 exchanges makes these issues doubly evident.