1031.Exchange INTELLIGENCE NETWORK
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EXCHANGE STRUCTURES

Exchange accommodation titleholder

Also called: EAT · accommodation titleholder

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PLAIN-ENGLISH DEFINITION

The person or entity that holds qualified indicia of ownership of parked property in a qualifying reverse or improvement exchange safe-harbor structure.

What it means in practice.

Rev. Proc. 2000-37 describes the EAT role within a qualified exchange accommodation arrangement.

Why it matters.

The EAT is central to many reverse and improvement exchange structures.

Additional notes.

Rev. Proc. 2000-37 describes the EAT role within a qualified exchange accommodation arrangement.

PRIMARY / REFERENCE SOURCES

Read the source material.

irs.gov ↗irs.gov/pub/irs-drop/rp-00-37.pdf
CONNECTED LANGUAGE

Related definitions.

Exchange StructuresEATAcronym for exchange accommodation titleholder.Exchange StructuresQEAAA safe-harbor parking arrangement described in Rev. Proc. 2000-37.Exchange StructuresParking arrangementA structure in which an accommodation party temporarily holds replacement or relinquished property as part of a reverse or improvement exchange.Exchange StructuresReverse exchangeA structure used when the replacement property is acquired before the relinquished property is transferred.
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