REV PROCRevenue Procedure (IRS)
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for relief or is denied relief under Rev Proc. 2013-30 may seek relief by requesting a PLR.
This Rev Proc requires that either the replacement property or relinquished property be parked with a qualified intermediary or an affiliate thereof during the exchange period since if the investor has title to both properties at one time there would be no exchange.
No, Rev Proc 2004-51 put an end to building on one's own property and taking title to such property as improved even if one transfers the property to an intermediary or other agent first which holds the property during the 180 day exchange/improvement period and then transfers it back as improved.
Rev Proc 2004-51 specifically disqualifies deferred exchanges where the property has been owned by the taxpayer any time within the last 180 days.
In order to qualify for the benefits of the Rev Proc, the following tests must be met:
Each tenant in common must be a party to any loan documents under the Rev Proc as well as for the benefit of the lender.