Revenue Procedures

Rev. Proc. 2008-16: Exchanges of Vacation Homes and Rental Property

This revenue procedure provides a safe harbor under which the Internal Revenue Service (the “Service”) will not challenge whether a dwelling unit qualifies as property held for productive use in a trade or business or for investment for purposes of § 1031 of the Internal Revenue Code.

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-kind exchanges. Parking transactions typically are designed to “park” the desired replacement property with an accommodation party until such time as the taxpayer arranges for the transfer of the relinquished property to the ultimate transferee in a simultaneous or deferred 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.

Rev. Proc. 2003-39: Like-Kind Exchange Programs

Safe harbor rules are provided under section 1031 of the Code, which allows for deferral of gain realized on a like-kind exchange of property, with respect to programs involving ongoing exchanges of tangible personal property using a single intermediary (“LKE Programs”). For purposes of this revenue procedure, an "LKE Program" is an ongoing program involving multiple exchanges of 100 or more properties. Although LKE Programs may differ in various ways, an LKE Program must have all of the following characteristics:

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

Rev. Proc. 92-91: Air Emission Allowances

The purpose of the Act is to reduce the impact of acid rain through a program of annual allocations of sulfur dioxide emission allowances ("allowances") to certain fossil-fuel-powered combustion devices ("units"), such as boilers, owned by electricity generating companies ("utilities"). The program will be administered by the Environmental Protection Agency (the "EPA") with enforcement beginning in 1995.

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