Learn the basics as well as the subtleties, pitfalls and advanced strategies of reverse exchanges.
Often, a real estate firm or investor identifies property that it desires to acquire with tax-deferred capital; however, the firm or investor is not yet ready to sell any of its property for use in a tax-deferred like-kind exchange under Internal Revenue Code § 1031. A 'reverse' like-kind exchange is a technique that allows holders of real estate to acquire 'replacement property' (generally) up to 180 days prior to its disposition of 'relinquished property' in a tax-deferred § 1031 exchange. This topic helps real estate holders and their advisors understand the mechanics of effectuating a reverse like-kind exchanges. Additionally, this material will educate you on the tax and practical considerations that arise when planning or during a reverse like-kind exchange. This topic will also cover certain special topics with respect to reverse like-kind exchanges, including tenancies in common, nonsafe harbor exchanges, and construction (build-to-suit) exchanges.
Agenda
Faculty
Aaron S. Gaynor
Roberts & Holland LLP
- Associate at Roberts & Holland LLP in New York, New York
- Tax practice focused on real estate industry, in particular, I.R.C. § 1031 like-kind exchanges and real estate investment trusts (REITs); other practice areas include New York State and City taxes (including realty transfer taxes and sales tax) and I.R.C. § 467 leases
- Regular panelist at Sales, Exchanges & Basis Committee of American Bar Association Tax Section
- Co-wrote (with Vivek A. Chandrasekhar) Techniques for Using Boot in a Like-Kind Exchange to Liquidate a Partner in a Real Estate Partnership, Tax Management Real Estate Journal (Vol. 32, No. 1, Jan. 6, 2016)
- Member of American Bar Association Tax Section (Sales, Exchanges & Basis Committee) and National Association of Real Estate Investment Trusts (NAREIT)
- J.D. degree, Benjamin N. Cardozo School of Law (Yeshiva University); LL.M. degree in taxation, New York University; B.A. degree, Brandeis University
- Can be contacted at [email protected]
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