Not be the Taxpayer, Agent of Taxpayer, or any other related party. Hold title to the property. Consistent tax treatment between Taxpayer and Accommodation Titleholder. Identification of Relinquished Property within 45 days Similar rules as with a Deferred Exchange. Taxpayer can loan money or guarantee loans Property can be leased to Taxpayer.
Taxpayer can manage the property, make improvements or provide other services.
Puts and calls at fixed prices are okay. Steps in a Reverse Exchange Taxpayer enters into a contract to acquire a potential replacement property and arranges acquisition financing, in the form of seller financing, third party financing, or the Taxpayer advances the acquisition funds. The AT acquires title to the Parked Property, with financing arranged by the Taxpayer and sometimes guaranteed by the Taxpayer. Within 45 days of the AT' s acquisition of the Parked Property, the Taxpayer identifies one or more Relinquished Properties. Identification to be delivered to AT and under the same guidelines as the Deferred Exchange.