Using Like-Kind Exchanges to Minimize a Foundation’s Investment Income Tax—Part II
Author: Katherine E. David.
Source: Volume 32, Number 02, Winter 2015 , pp.41-53(13)
< previous article |next article > |return to table of contents
Abstract:
The first article in this two-part series explained the application of Internal Revenue Code Section 4940 to gains from the sale of property and described certain basic requirements of a Section 1031 exchange. This article explains the mechanics of more complex transactions that qualify as “exchanges” under Section 1031 and that, by extension, should qualify under Section 4940. It also discusses the circumstances in which a particular transaction structure might be most appropriate.Keywords: deferred forward exchanges; sale of relinquished property; qualified intermediaries; “Exchange First”; “Exchange Last”; IRC Sec. 1031; IRC Sec. 4940; net investment income
Affiliations:
1: Strasburger & Price, LLP.