21. What is a reverse exchange?

Again, a delayed or deferred exchange is defined as those transactions in which a taxpayer transfers the relinquished property in exchange pursuant to the 45-day/180 day provisions enacted by Congress in 1984. Reverse Exchanges are when an individual wish to exchange property they own for property that must be acquired prior to the sale of the relinquished property. In a true reverse (or "Reverse Starker") exchange, the exchanger acquires the replacement property before conveying the relinquished property. The IRS in Revenue Procedure 200-37 issued rules addressing or allowing true reverse exchanges. As the taxpayer you will enter into a Qualified Exchange Accommodation Agreement (QEAA) and an Exchange Accommodation Title Holder (EAT) will acquire the replacement property. You must then identify your disposition property within 45 days and actually dispose of it by the 180th day.

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