![]() ![]() The replacement period would still end 180 days after the transfer of the relinquished property under Notice 2020-23. It’s worth noting that in situations where the 45-day extension period is set to end between April 1 and July 15, but the 180-day replacement period falls beyond July 15, only the 45-day identification period is extended. Section 301.7508A-1(c)(1)(iv)–(vi) of the Procedure and Administration Regulations.While the Notice doesn’t refer to Section 1031 directly, it does appear that a taxpayer currently in the exchange process would be considered an “affected taxpayer.” An “affected taxpayer” is defined in the Notice as any person performing a time-sensitive action listed in the following to be performed on or after April 1, 2020, and before July 15, 2020: ![]() This applies to both forward exchanges and safe harbor reverse exchanges under Revenue Procedure 2000-37. If either period deadline falls between April 1 and July 14, the new deadline is now July 15, 2020. IRS Notice 2020-23, released on April 9, 2020, provides for extensions to both the 45-day identification period and the 180-day replacement period if either period is set to end between April 1 and July 15, 2020. In their latest Emergency Declaration aimed at helping American taxpayers, the Department of Treasury and the Internal Revenue Service provided a deadline extension for taxpayers currently in the process of completing Section 1031 like-kind exchanges. ![]()
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