Other LKE Opportunities

PwCs Washington National Tax Services (WNTS) and Tax Projects Delivery Group (TPDG) team together to provide taxpayers with like-kind exchange (LKE) services. The WNTS and TPDG professionals have a wide-variety of experience with exchanges and can provide practical advice and services in a timely fashion. These services may help you to defer gain on the disposition of a wide-variety of capital assets.

Background

Under IRC section 1031, taypayers may defer the gain realized if certain capital assets are "exchanged" for assets of a like-kind. While many taxpayers are familiar with the LKE rules and may have used them, recent developments have made the LKE rules a more broadly applicable tax-deferral tool for taxpayers, than previously thought.

Recent developments include:

  • Revenue Procedure 2000-37 on "reverse exchanges" including parking transactions and build-to-suit exchanges.

  • Revenue Procedure 2002-22 on the use of fractional interests in real estate as replacement property in LKEs.

  • Use of step-in-the-shoes depreciation in LKEs and the effect of the new bonus depreciation rules.

  • Private letter rulings and TAMs on intangible exchanges, non-safe harbor reverse exchanges, vehicle leasing LKE programs, the use of agency law to reduce transfer taxes, and the use of e-commerce to simplify LKE mechanics.

  • Forthcoming IRS guidance on vehicle leasing LKE programs and other LKE programs.

  • Emergence of syndicators promoting pre-packaged replacement property for LKEs.

These developments have also increased the complexity of the LKE rules and the need for taxpayers to have access to LKE professionals who can provide advice and solutions in a creative and cost-effective manner.

PricewaterhouseCoopers offers a number of like kind exchange programs that may benefit you in deferring taxable gains.The sections that follow provide more detail on some of these programs.

 
CapExchange

CapExchange is a like kind exchange program that assists companies in deferring the gains on the disposition of their assets, despite the fact that they may not have plans to purchase specific replacement property. More...
 
LKE for Intangible Assets

Internal Revenue Code 1031(a) provides that no gain or loss is recognized if qualifying property is exchanged for other qualifying property of a "like kind." Treas. Regs. 1.1031(a)-2(c) addresses the like kind requirement as applied to the exchange of intangible assets. More...
 
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