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.