IRS Private Letter Ruling PLR 200251008
Taxpayer is an S corporation, organized under the laws of State A, which operates Business on a calendar year basis, using the accrual method of accounting. Business is situated on RQ. Taxpayer
Understanding the Impact of Depreciation on Like-Kind Exchanges
The U.S. Treasury does not lose cash revenue from an exchange because the taxpayer must forego future depreciation deductions. Read this paper from the Federation of Exchange Accommodators that
Nevada Exchange Facilitator Code
Washington Qualified Intermediary Regulation
ENGROSSED SUBSTITUTE SENATE BILL 5082 AS AMENDED BY THE HOUSE Passed Legislature 2013 Regular Session State of Washington 63rd Legislature 2013 Regular Session By Senate Financial
IRS Private Letter Ruling PLR 200329021
Parent is a publicly-traded State A corporation that is engaged in the business of owning and operating C Facilities. Parent is the sole shareholder of several subsidiaries, including Taxpayer.
Virginia Exchange Facilitators Act
HOUSE BILL NO. 417 AMENDMENT IN THE NATURE OF A SUBSTITUTE (Proposed by the House Committee on Commerce and Labor on January 21, 2010) (Patron Prior to Substitute––Delegate
IRS Private Letter Ruling PLR 201408019
Taxpayer is a limited liability company that is treated as a partnership for federal income tax purposes. Taxpayer uses an overall accrual method of accounting for filing its federal income tax
Understanding Tax-Deferred Exchanges of Real Estate
The concept of tax-deferred exchanges is quite simple: If one trades property for like-kind property and does not receive any cash or other non-like-kind property, then no profit has been made, and
New Hampshire 1031 Exchange Law
This bill recognizes Internal Revenue Code section 1031 like-kind exchanges which use federally disregarded entities as the recipient of replacement property, but emphasizes the character of such
1031 Exchange Cooperation Clause
Due to changes in 1031 exchange over the years, it is no longer a requirement to disclose that a
Section 1031 Tax Deferred Exchanges - A Review of the Final Regulations
Tax deferred exchanges of real estate have been recognized by the Internal Revenue Code since the 1920s. A variety of factors have converged the past several years leading to a dramatic increase in
Tax Deferred Exchanges
It happens all the time. A call comes in from a knowledgeable accountant: “We have a client who is replacing equipment and wants to defer paying taxes. We need some help with an IRC section 1031
Deferred Exchanges: Avoiding Traps for the Unwary
Tax-deferred exchanges of real estate have been recognized by the Internal Revenue Code since the 1920s. Recently, various factors have converged leading to a marked increase in the use of
IRS Issues Long Awaited Reverse Exchange Rules
During the one-year period between the promulgation of the 1990 proposed exchange regulations and the issuance of the final regulations in April of 1991, the IRS solicited comments in regard to
Internal Revenue Service Regulations: IRC §1031
Like-Kind Exchange: Additional Rules for Exchanges of Personal Property and for Exchanges of Multiple Properties This document contained final regulations relating to exchanges of
Internal Revenue Code Section 1031
Under Internal Revenue Code (IRC) section 1031, no gain or loss is recognized when companies sell business or investment property and acquire property that is like-kind. A transaction that is
IRS Private Letter Ruling 200912004
Cars, light general purpose trucks (for use over the road having actual unloaded weight of less than 13,000 pounds) and vehicles that share characteristics of both cars and light general purpose
Like-Kind Classification Codes
Depreciable tangible personal property is exchanged for property of a "like-kind" under section 1031 if the property is exchanged for property of a like-kind or like class. Depreciable tangible
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
Notice 2005-3
Additional Relief for Like-Kind Exchanges for Which Deadlines May Be Postponed Under §§ 7508 and 7508A of the Internal Revenue Code This notice advises taxpayers
IRS Private Letter Ruling 200236026
A, a wholly owned subsidiary of B, is engaged in the business of m. A, a calendar year taxpayer, files a consolidated income tax return as part of an affiliated group of corporations. All of the
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
Rev. Proc. 2010-14: Safe Harbor Treatment for Failed 1031 Exchanges Involving QI Defaults
This revenue procedure provides a safe harbor method of reporting gain or loss for certain taxpayers who initiate deferred like-kind exchanges under § 1031 of the Internal Revenue Code but fail to
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
Chief Counsel Advice 20125049: Rental Equipment
Is Corporation X allowed depreciation deductions under § 167 of the Internal Revenue Code and like-kind exchange treatment under § 1031 for equipment that Corporation X simultaneously held for
Maine Public Law 61: Regulation of Exchange Accommodators
PUBLIC Law, Chapter 61 LD 165, item 1, 124th Maine State Legislature An Act To Supervise and Regulate Real Estate Settlement Agents and Exchange Facilitators in Order To Protect Consumers
Transport Topics: Eliminate Unnecessary Taxes
Due to the expiration of bonus depreciation, trucking companies are facing significant tax liabilities for 2014. This Transport Topic column offers strategies and solutions for mitigating the huge
California SB 1007: Qualified Intermediary Regulation
An act to add and repeal Division 20.5 (commencing with Section 51000) of the Financial Code, relating to exchange facilitators.  SB 1007, Machado. Exchange facilitators. Existing law
Kreisers Inc. v. First Dakota Title Limited
Kreisers Inc. hired First Dakota Title to assist it with a property exchange in order to receive tax deferred benefits under 26 U.S.C. § 1031. After a partial failure of that exchange, Kreisers
Colorado HB 1254: Exchange Facilitator Legislation
HOUSE BILL 09-1254   BY REPRESENTATIVE(S) Judd, Rice, Ryden, Pommer; also SENATOR(S) Harvey, Carroll M., Hodge, Penry.       CONCERNING ADDITIONAL CONSUMER
IRS Private Letter Ruling 200148042
For Customer to obtain the benefits of the safe harbor rules of Rev. Proc. 2000-37, the transaction need only fit within the confines of the safe harbor rules. Assuming the boundaries of the safe
Idaho Escrow Act Policy Statement #2007-4
INTERPRETATIONS OF THE IDAHO ESCROW ACT The Idaho Escrow, Idaho Code§ 30-901 et seq., (the Act) became law in Idaho on July 1, 2005. In an effort to provide direction to Idaho businesses
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