Laws, Regulations & Annotations

Property Taxes Law Guide – Revision 2018

Property Tax Annotations

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Annotation 220.0198

220.0198 Exchange. An owner of real property contemplated a transfer through the use of a reverse exchange in which the subject property is first transferred to another with instructions to sell the property when a buyer becomes available. The transaction was not consummated within the six-month safe harbor period required by Internal Revenue Code section 1031, however, and the property was reconveyed to the owner by means of a deed in lieu of foreclosure. Neither the conveyance nor the reconveyance resulted in a change in ownership because each of those transfers involved only the transfer of legal title to the property, not a transfer of the beneficial interest in the property, which is a required element of change in ownership. C 8/16/2001.