1031.Exchange INTELLIGENCE NETWORK
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OWNERSHIP & ENTITIES

Taxpayer

Also called: exchanger · exchange taxpayer

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PLAIN-ENGLISH DEFINITION

The person or entity whose property is being exchanged and whose tax treatment is at issue.

What it means in practice.

Exchange documents, ownership and reporting should be coordinated around the actual taxpayer. Entity changes around an exchange can create technical issues requiring professional review.

Why it matters.

Professionals often use “exchanger” as industry shorthand for the taxpayer completing the exchange.

Additional notes.

Exchange documents, ownership and reporting should be coordinated around the actual taxpayer. Entity changes around an exchange can create technical issues requiring professional review.

PRIMARY / REFERENCE SOURCES

Read the source material.

irs.gov ↗irs.gov/instructions/i8824
CONNECTED LANGUAGE

Related definitions.

Ownership & EntitiesSame-taxpayer principleIndustry shorthand for the need to maintain appropriate taxpayer continuity between the relinquished and replacement sides of an exchange.Ownership & EntitiesDisregarded entityAn entity that is ignored as separate from its owner for certain federal income-tax purposes.
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