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Course Details

Reverse Like-Kind Exchanges

Webinar: ID# 1023913
Recorded CD
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About This Course:
A ‘reverse' like-kind exchange is a technique that allows holders of real estate to acquire ‘replacement property' (generally) up to 180 days prior to its disposition of ‘relinquished property' in a tax-deferred § 1031 exchange.

This webinar will cover reverse like-kind exchanges, including tenancies in common, non-safe harbor exchanges, and construction (build-to-suit) exchanges. It helps real estate holders and their advisors understand the mechanics of effectuating a reverse like-kind exchanges.

Additionally, this material will educate you on the tax and practical considerations that arise when planning or during a reverse like-kind exchange.

AGENDA

Introduction
  • What Is a Reverse-Like Kind Exchange?
  • When Is It Appropriate to Undertake a Reverse Like-Kind Exchange? - Tax and Practical Considerations
Like-Kind Exchanges, Generally
  • BULLET 1
  • Basic Requirements
  • Safe Harbors
  • Qualified Intermediary
  • Qualified Escrow Accounts and Qualified Trusts
"Safe Harbor" Reverse Like-Kind Exchanges (Under Rev. Proc. 2000-37)
  • Setting up the Exchange
  • "Exchange Last" or "Exchange First"
  • Qualified Exchange Accommodation Arrangements and Use of Exchange Accommodation Titleholder (EAT)
  • Permitted Arrangements Between EAT and Taxpayer
  • Use of Disregarded Entities
  • Lender Considerations
  • Transfer Taxes
  • "Parking" Period
  • Unwinding the Arrangement
  • Transfer of Replacement Property
  • Transfer Taxes
Special Topics
  • Tenancies in Common
  • Non–Safe Harbor Reverse Like-Kind Exchanges
  • Construction (Build to Suit) Exchanges
About The Presenter

Aaron S. Gaynor
  • Associate at Roberts & Holland LLP in New York, New York
  • Tax practice focused on real estate industry, in particular, I.R.C. § 1031 like-kind exchanges and real estate investment trusts (REITs); other practice areas include New York State and City taxes (including realty transfer taxes and sales tax) and I.R.C. § 467 leases
  • Regular panelist at Sales, Exchanges & Basis Committee of American Bar Association Tax Section
  • Co-wrote (with Vivek A. Chandrasekhar) Techniques for Using Boot in a Like-Kind Exchange to Liquidate a Partner in a Real Estate Partnership, Tax Management Real Estate Journal (Vol. 32, No. 1, Jan. 6, 2016)
  • Member of American Bar Association Tax Section (Sales, Exchanges & Basis Committee) and National Association of Real Estate Investment Trusts (NAREIT)
  • J.D. degree, Benjamin N. Cardozo School of Law (Yeshiva University); LL.M. degree in taxation, New York University; B.A. degree, Brandeis University
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Reverse Like-Kind Exchanges
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