PwC’s 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.
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:
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.
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.
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.