Guidance from the IRS on making reverse-starker exchanges

Rev. Proc. 2000-37 attempts to extend to reverse Starker exchanges certain safe harbor procedures that are at least somewhat equivalent to those available under the regulations for regular Starker transactions. In particular, the new revenue procedure now offers reverse-Starker exchangers an opportu...

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Bibliographic Details
Published inTaxes Vol. 79; no. 2; p. 16
Main Authors Bryant, Jeffrey J, Alltizer, Richard L
Format Trade Publication Article
LanguageEnglish
Published Riverwoods CCH INCORPORATED 01.02.2001
Subjects
Gain recognition
Internal Revenue Code
Like kind exchange
Rev. Proc. 2000-37
Revenue procedures & rulings
Safe harbor
Section 1031
Tax deferred privileges
Taxpayers
Third party
United States > US
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Summary:Rev. Proc. 2000-37 attempts to extend to reverse Starker exchanges certain safe harbor procedures that are at least somewhat equivalent to those available under the regulations for regular Starker transactions. In particular, the new revenue procedure now offers reverse-Starker exchangers an opportunity to use an intermediary in the form of an exchange accommodation titleholder, who will not be treated as the taxpayer's agent. The revenue procedure clings to the formality that the receipt of replacement property prior to the transfer of relinquished property disqualifies the transaction as a Section 1031 like-kind exchange.
ISSN:0040-0181