IRS Issues PLRs Approving Two-Party Tenancy-in-Common Ownership Arrangements in 1031 Exchange

This update is courtesy of www.rees1031.com

In three recent private letter rulings (”PLRs”), the IRS ruled that two 50% undivided fractional interests in real property did not constitute an interest in a business entity for purposes of qualification as eligible replacement property in a IRC s. 1031 exchange.  The rulings are also significant in that they provide additional flexibility to two-party 50% tenancy-in-common ownership structures with regard to qualification as eligible replacement property compared to other tenancy-in-common ownership structures.

For the full report and additional information, please click:
http://www.rees1031.com/documents/TaxUpdate090908.pdf

Leave a Reply