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Using Like-Kind Exchanges to Minimize a Foundation’s Investment Income Tax—Part II  


Author:  Katherine David.


Source: Volume 13, Number 05, July/August 2014 , pp.11-16(6)




Family Foundation Advisor

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Abstract: 

The first article in this two-part series explained the application of IRC §4940 to gains from the sale of property and describes certain basic requirements of an IRC §1031 exchange. This article explains the mechanics of more complex transactions that qualify as “exchanges” under IRC §1031 and that, by extension, should qualify under IRC §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” and “Exchange Last”;IRC §4940 tax on net investment income

Affiliations:  1: Strasburger & Price, LLP.

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