Description
Learn about the key issues impacting real estate 1031 likekind exchanges.This topic covers critical IRS time deadlines in delayed exchanges, likekind requirements including creative property variations like easements, transferable development rights, oilgasminerals rights, vacation homes held for investment, fractional ownership (DST and TICs) , partnershipLLC scenarios (and how to best structure in advance of a 1031 exchange), reverse and improvement exchanges, related party transactions and how to avoid common pitfalls and other 1031 related issues. The information will provide a summary of current developments regarding applicable revenue rulings, PLR’s and other recent IRS guidance on current issues related to 1031 exchanges including how to help taxpayers owning commercial property in an LLC or partnership plan in advance to help avoid issues at closing if only some of the LLC members or partners want to exchange including the drop and swap, swap and drop and Partnership Installment Note (PIN) approaches. Finally, this will include a brief overview of what works and what does not when combining Qualified Opportunity Zones with 1031 Exchanges.
Date: 2019-11-25 Start Time: End Time:
Learning Objectives
Understanding the Capital Gain and the Impact of Taxes
• Depreciation Recapture
• Federal Capital Gain Taxes
• Net Investment Income Tax
• State Taxes
IRC Section 1031 Provision
• Exceptions
Partnerships/LLCs in a 1031 Exchange
• Drop and Swap
• Swap and Drop
• Court Holdings Case and Other Tax Court Decisions
• Partnership Installment Note (PIN) Under Section 453
Related Parties
• Who Is a Related Party
• Related Party Swaps
• Selling to a Related Party
• Buying From a Related Party
• Buying From a Related Party Who Is Also Exchanging
• Applicable Related Party PLRs, Revenue Procedures and Tax Court Decisions
Like-Kind Property
• What Qualifies and What Does Not Qualify
• Transferable Development Rights
• Water Rights
• Easements
• Energy (Oil, Gas, Minerals)
• Vacation Homes and Revenue Procedure 2008-16
• Delaware Statutory Trusts (DSTs)
Exchange Variations
The Delayed Exchange Process
• Identification Time Deadline
• Exchange Period Time Deadline
• Identification Rules
• How to Properly Identify Property
• G(6) Restrictions in a Delayed Exchange
• What Not to Do in a Delayed Exchange
Parking Arrangements
• Revenue Procedure 2000-37
• Reverse Exchanges
• Improvement Exchanges
• Reverse Improvement Exchanges
• Qualified Opportunity Zones and 1031 Exchanges
Qualified Intermediary Due Diligence
CLE (Please check the Detailed Credit Information page for states that have already been approved) ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.
Scott R. Saunders-Asset Preservation Inc.
