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Effective September 15, 2000, Revenue Procedure 2000-37, Section 3, paragraph .02 states “…the Service recognizes that “parking” transactions can be accomplished outside of the safe harbor provided in this revenue procedure. Accordingly, no inference is intended with respect to the federal income tax treatment of “parking” transactions that do not satisfy the terms of the safe harbor provided in this revenue procedure, whether entered into prior to or after the effective date of this revenue procedure.”
Private Letter Ruling 200111025 approves a non safe harbor exchange where the parking period was 18 months. Private Letter Rulings can be secured with the assistance of your accountant and can take upwards of six months for a position letter from the IRS. These position letters are specific to the Exchangor’s circumstances and cannot be relied upon as precedence.
Non safe harbor exchanges are inherently risky given they are outside the traditional 180 days.
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Andrew W. Gustafson,
CES®
Managing Member
Atlas 1031 Exchange, LLC
Toll Free: 866.521.1031 | EFax: 850.201.6911
Dallas: 214.523.9067 | Destin: 850.837.1031 |
Houston: 713.821.1776
Email: andgus@atlas1031.com
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Atlas 1031 Exchange, LLC is a Qualified Intermediary and does
not provide advice regarding specific tax consequences of IRC 1031 tax
deferred exchanges. Investors are encouraged to seek the
counsel of their attorney and accountant.
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Atlas 1031 Exchange, LLC. All rights reserved. Site designed by VTD, Inc.
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