Rev. Proc. 2010-14: Safe Harbor Treatment for Failed 1031 Exchanges Involving QI Defaults

This revenue procedure provides a safe harborsafe harbor method of reporting gain or loss for certain taxpayers who initiate deferred like-kindlike-kind exchanges under § 1031 of the Internal Revenue CodeInternal Revenue Code but fail to complete the exchange because a qualified intermediaryqualified intermediary (QI) defaults on its obligation to acquire and transfer replacement propertyreplacement property to the taxpayertaxpayer .