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Alternative Structures for Section 1031 Exchanges


Reprinted from Tax Notes, November 20, 2017, p. 1121

(Aresh Homayoun is of counsel in the Washington office of Morris, Manning & Martin LLP, Michael J. Rhim is a partner in the firm’s Atlanta office, and Chandler A. Michael is an associate based in the firm’s Raleigh-Durham, North Carolina, office. In this article, Homayoun, Rhim, and Michael discuss alternatives to the traditional section 1031 exchange for investing proceeds from the sale of property.)

I. Background
With the recovery of the real estate sector from the carnage of the Great Recession, the desire to avoid tax on gain realized in dispositions of appreciated real estate has brought renewed vigor to the 1031 exchange market.

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