IPA Joins Coalition Letter Requesting Additional Clarifications Around 1031 Deadlines
The IPA today joined a coalition of real estate associations in submitting a letter to the U.S. Treasury Department (the Treasury) requesting additional clarifications regarding previously set forth extensions for critical 1031 like-kind exchange deadlines under Notice 2020-23.
More specifically, the letter seeks clarification as to whether or not Section 17 of Rev. Proc. 2018-58 applies to 1031 like-kind exchanges. Unlike previous relief notices issued by the Treasury, Notice 2020-23 does not make any specific reference to Section 17. The letter requests additional clarification as to whether or not taxpayers engaged in 1031 like-kind exchanges are extended the critical relief outlined in Section 17.
The coalition also requested that March 13, 2020 be deemed the beginning date of disaster relief regardless whether or not this date is designated under Section 17, and that each day of the disaster period from March 13 to July 15, 2020 be treated as the date of the federally declared disaster.
Lastly, the coalition requested that if the end of the 45-day identification period or the end of the 180-day exchange period applicable to like-kind exchanges falls within the Notice 2020-23 disaster period of March 13, 2020 to July 15, 2020, that the deadlines to complete both of those actions be extended by 120 days or to July 15, 2020, whichever is later.
If you have any questions, please don’t hesitate to reach out to myself or Tony.
SVP, Government Affairs and General Counsel
Institute for Portfolio Alternatives