The service stated that where, under state law, water rights are real property rights, the exchange of perpetual water rights for a fee interest in land constitutes a nontaxable exchange of property of like-kind within the meaning of section 1031, provided section 1031's requirements as to ...
TCJA 包括一项过渡规则,如果在 2017 年 12 月 31 日之前出售了原始财产或收购了替换财产,则允许在 2018 年进行 1031 合格个人财产的交换。 过渡规则是特定于纳税人的,不允许在出售旧财产之前购买新财产的反向 1031 交换。 重要:公司股票或合伙权益的交换从来没有符合条件——现在仍然没有——但作为房地产共同承租...
of section 1036(a), or of section 1037(a), if it were not for the fact that the property received in exchange consists not only of property permitted by such provisions to be received without the recognition of gain, but also of other property or money, then the gain, if any, to...
He rules that they have a claim, but "Summary Judgment is denied as to the proof of claim's secured status." No cigar, no money. Again, as Frank R. Alley III did before him, Radcliffe, in July 2006, claimed a conflict of interest and ordered the case transferred from Eugene, Oregon...
Parr, Jason J