Sentences with phrase «exchange accommodation arrangement»

This procedure provides a safe harbor under which the Service will not challenge (a) the qualification of property as either «replacement property» or «relinquished property» for purposes of section 1031 of the Code or (b) the treatment of the» «exchange accommodation titleholder» as the beneficial owner of such property for federal income tax purposes, if the property is held in a «qualified exchange accommodation arrangement» (QEAA).

Not exact matches

At the annual ICE Exchange held in San Antonio, Texas, November 11 - 14, 2014, House Counsel Balasa was the co-presenter for two education sessions: «Key Legal Issues for Certification Entities: Perspectives of General and Staff Counsel,» and «Special Arrangements: Accommodations 101.»
Revenue Procedure 2000 - 37 allows the Exchange Accommodation Titleholder and the Investor to enter into a number of non-arms length contractual arrangements to complete a Reverse Exchange transaction.
You will enter into an agreement called the Qualified Exchange Accommodation Agreement or «QEAA» that will define and structure the parking arrangement to be used for your Improvement Exchange transaction.
You will enter into an agreement called the Qualified Exchange Accommodation Agreement or «QEAA» that will define and structure the parking arrangement to be used for your Construction Exchange transaction.
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