Relocation sales.

• Author: Laffie, Lesli S.
• Position: FROM THE IRS

In Rev. [Ltd. 2005-74, the IRS analyzed three transactions to determine whether each was (1) a sale of an employee's home to his or her employer through a relocation management company, acting as the employer's agent, followed by a separate sale of that home by the employer to a third-party buyer; or (2) one sale of the home from the employee to the third-party buyer, facilitated by the employer through the relocation management company.

Conclusions: Applying a benefits-and-burdens analysis to the transactions, the Service determined that two of the transactions resulted in two separate sales of the home. However, in the third case, the IRS concluded that, for Federal tax purposes, there was one sale of the home from the employee to the third party, facilitated...