LR 202053007
(12/31/2020) Series of Related Party Exchanges does not Violate Section 1031(f)
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By Mary Foster, Esq., CES®
This private letter ruling involves a series of exchanges by 5 related entities. It is similar to prior rulings issued by the IRS with the same analysis. In this ruling: (1) Taxpayer transferred its Relinquished Property to an unrelated person, and then acquired its Replacement Property from Related Party 1 and Related Party 2; (2) Related Party 1 acquired replacement properties from unrelated persons; (3) Related Party 2 acquired its Replacement Property from Related Party 3; (4) Related Party 3 acquired its Replacement Property from Related Party 4; and (5) lastly, Related Party 4 acquired its replacement property from unrelated persons.
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GAC Update - February 2021
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Work is underway in Congress on a budget reconciliation measure to implement President Biden’s American Rescue Plan. The legislation contains $1.9 trillion in COVID relief measures but is not expected to include tax items. Work on the reconciliation bill, which only requires a simple majority for passage, is expected to be completed by mid-March, when expanded unemployment benefits are set to expire.
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45 Day and 180 Day Postponements for Disaster Areas in Texas, Oklahoma, and Louisiana
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Texas: The IRS has issued postponements of the 45-day and 180-day deadlines for the entire State of Texas for the winter storm that began February 11, 2021.
Oklahoma: The IRS has issued postponements of the 45-day and 180-day deadlines for the entire State Oklahoma for the winter storm that began February 8, 2021.
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A Look at How the CES® Designation Came About
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In 1998, Margo Mucha McDonnell was chair of the FEA Continuing Education Committee and polled the volunteer committee members to determine the committee's goal for the upcoming year. Jim Casterline, a long time FEA Director and incoming President, recommended the FEA develop a certification program. Over the next few years, many committees assisted in polling the FEA general membership to determine whether members wanted to develop such a program. In 1999, Brad Penner became co-chair and helped create our Mission Statement. At the FEA Annual Conference and General Meeting in October 2000, the FEA membership overwhelming voted to proceed with a voluntary certification program. In 2001, the term Certified Exchange Specialist® (CES®) was chosen as the designation members wanted to use to convey their competence to taxpayers and their professional advisors.
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Like-Kind Exchanges Celebrate 100 Years in Tax Code
Century-Old Provision Will Be Vital in Reimagining Real Estate After Pandemic
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2021 marks the 100th year anniversary of like-kind exchanges in the Internal Revenue Code, according to the Federation of Exchange Accommodators, the industry association for the Qualified Intermediaries (QIs), or professionals who facilitate like-kind exchanges of real estate.
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1031 Exchange Services, LLC
Little Rock, AR (Regular Member)
Mercer 1031 Consulting, LLC
Boston, MA (Affiliate)
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Sorry Folks. The Battery Fairy Isn’t Coming.
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Educational Article Provided by FEA Affiliate Member: Peregrine 1031 Energy Partners. NOTE: These are the views of the author and not necessarily those of the FEA.
In 2019, the state of Minnesota consumed 72 million megawatt-hours of electricity. This means the amount of battery storage expected to be in existence for the entire world would be the equivalent of just one percent of Minnesota’s annual energy consumption.
Current cost estimates for battery storage are about $250 per kilowatt-hour, which equates to a cost of $250,000 per megawatt-hour. This means the cost of all the expected battery storage in the world (741,000 MWh by 2030) would cost $185 billion to build.
Add in the fact that battery storage only lasts for 10 years, according to the National Renewable Energy Laboratory.
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Nano Banc
(858) 880-5900 (Bobby) /
(844) 626-0262 Ext 712 (Michael)
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1031 Investment Services LLC
2 Orr Hatch Drive
Cornwall, NY 12518
(845) 534-6818 Phone
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FEA thanks our Affiliate Members for their support of our FEA members and the 1031 exchange industry. In return, FEA members are encouraged to support our Affiliate Members.
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1031 Investment Services LLC
(845) 534-6818
Axos Bank
(858) 732-1381
BankUnited
(914) 305-9428
Budget Mortgage Corp.
(410) 458-5747
Capital One
(631) 304-3061
Capital Square 1031
(804) 290-7900 Ext 132
Clark Wealth Strategies, Inc.
(402) 504-3531
Colorado Financial Service Corporation
(303) 962-7267
Customers Bank, CB Private & Commercial BKNG-NY
(212) 843-2488
Effective 1031 Planning
(888) 251-3004
Enterprise Bank & Trust
(760) 550-2030
ExchangeRight Real Estate, LLC
(855) 317-4448
First Foundation Bank
(949) 468-8559
Four Spring Capital Trust
(732) 749-7339
Independent Financial
(469) 301-2791
Inland Real Estate Group
(630) 218-4953
Kay Properties & Investments, LLC
(310) 404-7297
Lockton Insurance Brokers, LLC
(415) 568-4106
Luther Burbank Savings
(858) 436-1830
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Meltzer, Lippe, Goldstein & Breitstone, LLP
(516) 747-0300
Mercer 1031 Consulting, LLC
(866) 773-1031
Millwork Commercial
(801) 899-1943
Montego Minerals
(940) 395-4750
MNM Partners, LLC
(408) 221-3077
MUFG Union Bank, N.A.
(312) 601-3956
Nano Banc
(858) 880-5900
NexTrend Securities Inc.
(972) 661-1283
Northern Bank and Trust
(781) 569-1852
Passco Companies, LLC
(949) 263-7904
Peregrine 1031 Energy Partners
(214) 483-1997
Realized Holdings LLC
(512) 827-3651
Robbins May & Rich, LLP
(910) 692-4900
Signature Bank
(646) 822-1946
Stan Johnson Company
(646) 778-5560
Syndicated Equities
(312) 640-9028
Tangible Wealth Solutions
(720) 996-1794
TriState Capital Bank
(412) 304-0464
Umpqua Bank
(818) 254-3492
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From the FEA Executive Director's Desk
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Ways FEA Members Can Celebrate Like-Kind Exchanges Tax Code 100th Anniversary
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Utilize the press releases produced by FEA – include them in your company’s newsletter, post them on the website and distribute them to your customers.
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Link to FEA’s social media pages where and retweet, repost and repeat!
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Include the FEA logo with the 100th anniversary banner on your website and in your Email signature line.
- Educate your staff, your clients and your congressional delegation about this history of the 1031 exchange.
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Make plans to celebrate the 100th anniversary by attending the FEA Annual Conference in Chicago, IL in September
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1031 Boot Camp & 1031 Reverse Boot Camp Recordings Available for Purchase
Expand your knowledge of the 1031 industry through our two online offerings – 1031 Boot Camp and 1031 Reverse Exchange Boot Camp. Both three-hour sessions were recorded at the 2020 FEA Virtual Annual Conference. Unlimited access to the recordings and supporting materials can be purchased here Videos-on-Demand (1031.org)
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FEA Annual Conference Programming Announced
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FEA has selected programming for its 2021 Annual Conference with you in mind! Check out these topics:
- 1031 and 1031 Reverse Exchange Boot Camps
- Ethics
- New Regulations
- Economic update
- Legislation update
- Safety protocols (Like cyber security, insurance and mega-large deposits)
- Annual tax update
- Non-safe harbor
- Who’s the tax payer
- Tricky 1031 situations
- Procedural timeline tax controversy in 1031 Case
- Due diligence
- Personal use
- Diversity and inclusion
- Cannabis / cash business sales in a 1031
FEA Annual Conference
1031 – A Century of Growth
September 22–24, 2021
The Palmer House Hilton
17 East Monroe Street
Chicago, Illinois
#like-kindcelebrates100yrs
Click here for information to assist you with budgeting.
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MCLE Credit from California Received for the 2020 FEA Virtual Conference
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FEA has received the approval of MCLE credit for the 2020 Virtual Conference.
If you need to have the MCLE certificate reissued from FEA to reflect the approved hours, contact Denise Hoffman, CMP, meetings@1031.org.
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New Threats to Section 1031 Like-Kind Exchanges
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The FEA 1031PAC contributes to Members of Congress of both political parties. The FEA 1031PAC is funded by eligible individual employees. To become eligible, individuals must be employed by FEA member companies that have filed a Permission to Solicit form. A Permission to Solicit form is required by the Federal Election Commission before FEA can solicit eligible employees of member companies.
Member companies are only permitted to grant one trade association permission to solicit their employees per calendar year. Contact Lynn Harkin at director@1031.org for more information.
FEA Member Key Contacts can find a Permission to Solicit Form here.
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Federation of Exchange Accommodators
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