1031.Exchange INTELLIGENCE NETWORK
License territory Acquire
EXCHANGE STRUCTURES

Reverse exchange

Also called: parking exchange · replacement first exchange

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PLAIN-ENGLISH DEFINITION

A structure used when the replacement property is acquired before the relinquished property is transferred.

What it means in practice.

Rev. Proc. 2000-37 provides a safe harbor involving an exchange accommodation titleholder and a qualified exchange accommodation arrangement for certain “parking” structures.

Why it matters.

This is a specialized structure requiring coordination before acquiring the replacement property.

Additional notes.

Rev. Proc. 2000-37 provides a safe harbor involving an exchange accommodation titleholder and a qualified exchange accommodation arrangement for certain “parking” structures.

PRIMARY / REFERENCE SOURCES

Read the source material.

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

Related definitions.

Exchange StructuresExchange accommodation titleholderThe person or entity that holds qualified indicia of ownership of parked property in a qualifying reverse or improvement exchange safe-harbor structure.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 StructuresImprovement exchangeA specialized structure in which improvements to replacement property are incorporated into the exchange before the taxpayer receives the property.
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