Rev. Proc. 2000-37: Reverse Exchanges

Since the promulgation of the final regulations under § 1.1031(k)-1, taxpayers have engaged in a wide variety of transactions, including “parking” transactions, to facilitate reverse like-kindlike-kind exchanges. Parking transactions typically are designed to “park” the desired replacement propertyreplacement property with an accommodation party until such time as the taxpayertaxpayer arranges for the transfer of the relinquished propertyrelinquished property to the ultimate transferee in a simultaneous or deferred exchangedeferred exchange . Once such a transfer is arranged, the taxpayer transfers the relinquished property to the accommodation party in exchange for the replacement property, and the accommodation party then transfers the relinquished property to the ultimate transferee.