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Private Letter Rulings

Reaffirm IRS Position on Related Party Transactions
PLR 200820017 and PLR 200820025 Reaffirm IRS Position on Related Party Transactions Courtesy of the Federation of Exchange Accommodators In PLR 200820017 and PLR 200820025, both issued on February 7, 2008...
IRS OKs Exchange of Leaseholds and Personal Property
PLR 200842019 The transaction involved the exchange of leases, leasehold improvements and office equipment and furnishings. The taxpayer leased a portion of a building which grew too small for its needs...
Replacement Property Contributed to a Newly Formed Partnership Upon Termination of Private Testamentary Trust Still Qualifies for Deferral
In Letting Ruling 200812012 Replacement Property Contributed to a Newly Formed Partnership Upon Termination of Private Testamentary Trust Still Qualifies for Deferral Courtesy of the Federation of Exchange...
(Acquisition of Replacement Property from Related Party) Courtesy of the Federation of Exchange Accommodators
IRS Letter Ruling 200810016 (Acquisition of Replacement Property from Related Party) Courtesy of the Federation of Exchange Accommodators Following the holding of earlier rulings on the same topic, this...
(Replacement Property from Related Party)
IRS Letter Ruling 200807005 (Replacement Property from Related Party) Courtesy of the Federation of Exchange Accommodators Following the holding of earlier rulings on the same topic, this ruling holds...

IRS Letter Ruling 200805012 held that Transferable Development Rights (“TDR”) are like-kind for purposes of §1031 to a fee interest in real estate. Courtesy of the Federation of Exchange Accommodators...
Taxpayer able to Revoke Inadvertent Opt-Out from Installment Method in a Failed Exchange
IRS Letter Ruling 200813019 Permits Taxpayer to Revoke Inadvertent Opt-Out from Installment Method in a Failed Exchange Courtesy of the Federation of Exchange Accommodators PLR 200813019, issued on December...
EAT Acquires Partnership Interest ( Release Date 2/27/2009)
PLR 200909008:  EAT Acquires Partnership Interest  ( Release Date  2/27/2009) This ruling concludes that an EAT may acquire a 50% partnership interest as replacement property for the taxpayer’s...
PLR 200921009 - Section 1033 - Involuntary Conversions
Release Date: 5/22/2009 Date: February 13, 2009 This is in response to your request for a private letter ruling dated July 10, 2008, on the proper treatment of the reinvestment of condemnation proceeds...
PLR 201024036 (6/18/2010). Exchange of Emission Credits
This ruling holds that Parent corporation of consolidated group can acquire Sub’s emission reduction credits for nitrous oxide (NOx) and then exchange them under Section 1031 for volatile organic...

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