REQUIREMENTS FOR A QUALIFIED EXCHANGE
Section 1031 of the Internal Revenue Code specifies that the properties must be held for investment or business
purposes and that these properties being exchanged must be
“like-kind,” referring to the type of property being exchanged
(real estate, personal property, etc.) Qualifying property is broadly defined, for both the property being
transferred and that received, as realty used for investment or
business purposes.
In effect, all investment real estate, whether it is an office
building, farm, ranch, or a vacant lot, can be exchanged to any other piece of
investment property. Investment real estate can be exchanged for real property used
in a trade or business and vice versa.
IRC Tax Code states the
following are not considered
"like-kind". These include:
-
Stock in trade or other property held primarily for sale (e.g.
dealer property)
- Stocks, bonds, or notes (REITS
ARE NOT "Like Kind")
-
Other securities or evidences or indebtedness
- Interests in a partnership
-
Certificates of trusts or beneficial interest
- Partnership interests
QUALIFIED
INTERMEDIARY:
Section 1031 describes the need of a “safe harbor,” such as a
Qualified Intermediary (QI), to facilitate the exchange. The
exchanger must not have “Constructive Receipt” of the sale
proceeds – no cash or other benefits can go to the exchanger;
If an exchanger actually or constructively receives non-like-kind
property known as boot (e.g., money or personal property) for the
relinquished realty anytime before receiving the like-kind replacement
property, the transaction is a sale and not a deferred exchange.
As a result, the structuring of a deferred real property exchange
requires documentation to support an interdependent and integrated
transaction with the sale proceeds not being paid to the exchanger at
the settlement date (or held in escrow).
The Buy/Sell Contract should
contain wording similar to the following:
“Buyer hereby acknowledges that it is the intent of the Seller
to effect an IRC §1031 tax deferred exchange which will not delay
the closing or cause additional expenses to the Buyer. The
Seller’s rights under this agreement may be assigned to a
Qualified Intermediary, named by Seller, for the purpose of
completing such an exchange. Buyer agrees to cooperate with the
Seller and the Qualified Investor in a manner necessary to complete
the Exchange.”
Qualified Intermediary Rules
Include:
- QI is an entity or individual independent of the exchanger and
not deemed to be its agent, either objectively or subjectively.
Under the objective test, the QI cannot be the taxpayer’s closing
attorney or anyone else who has had a business relationship with the
exchanger during the last two years.
- The QI is the recipient of the net proceeds from the closing of the
relinquished property, with the money impounded for subsequent
reinvestment into other realty. Any earnings on these monies may
not be paid to the exchanger until the end of the exchange.
-
In a three-party deferred exchange, the QI is the third party, with
the other two being the exchanger and the replacement property owner.
- IRS Revenue Ruling 2002-83 prohibits a QI from using the impounded
funds to acquire the property of a party related to the exchanger to
be used as the replacement realty. Such a disposition by the related
party would be deemed a sale under IRC 1031(f), precluding any party
from cashing out during the two-year period following the exchange.
IDENTIFICATION OF
A REPLACEMENT PROPERTY:
There are three ways to identify properties the exchanger wishes to
purchase. The most common is the “3-property” rule.
In this rule, the identification period begins with the sale of the
relinquished property and gives the exchanger 45 days to identify up
to 3 possible investment properties. If the exchanger has no
possible exchange properties at the end of this 45 day time period, or
the properties that were identified are no longer available, then the
exchange is busted and the exchanger must pay the capital gains tax.
To
Identify Replacement Property it must be:
- 1.
identified in a written agreement using a portion of the
impounded funds for the earnest money deposit; or
- 2.
designated as replacement property in a written document signed
by the exchanger and hand-delivered, mailed, faxed, or otherwise
received by the Qualified Intermediary before the end of the identification period.
The regulations permit more than one property to be identified as
replacement property. The maximum number of replacement
properties which the exchanger may identify under the regulations is
as follows:
- 1.
Three properties of any fair market value (FMV); or
- 2.
Any number of properties, as long as the aggregate FMV of all
properties identified as of the end of the identification period
does not exceed 200% of the aggregate FMV of all relinquished
properties as of the date of transfer; or
- 3.
Under the 95% rule, an exchanger is permitted to identify any
number of properties of any total value, provided that 95% of what
has been identified is actually acquired within the 180-day
replacement period.
Replacement property acquired during the 45-day period reduces the
number of properties that can be identified under the above rules.