SAFE HARBOR RULES FOR REVERSE EXCHANGES.

• Author: Counts, James C. II
• Position: Brief Article

The IRS recently announced safe harbor rules for IRC Sec. 1031 exchanges where replacement property is acquired before the relinquished property is transferred. Rev. Proc. 2000-37 states the IRS will not challenge certain aspects of a reverse-Starker exchange if the property is held in a "qualified exchange accommodation arrangement."

During the nine years since regulatory guidance for deferred exchanges was promulgated, many different methods of reverse like-kind exchanges have been developed. The new Rev...