EXCHANGE STRUCTURE

Partial 1031 Exchange

An exchange does not always have to defer every dollar of gain—but partial deferral should be modeled deliberately.

Partial deferral can be intentional.

An investor may choose to receive some cash or other non-like-kind value while completing an exchange with the balance. Federal rules can require recognition of gain to the extent of money or non-like-kind property received, subject to the applicable calculations.

The decision should be modeled rather than guessed. Basis, debt, expenses, closing credits and cash retained can affect the result. A tax professional should calculate the expected recognized gain and replacement basis before the structure is finalized.

Primary / reference sources

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