1031 Tax Update
IRS PLR 200807005 approves of “Single Member Limited Partnership” as a disregarded entity. | |
In PLR 200807005, the IRS explicitly approved an arrangement where the taxpayer proposed to acquire replacement property in a like-kind exchange by acquiring 100% of the interest in a limited partnership that owned the replacement property. The replacement property is owned by a multimember limited partnership (the “LP”). Taxpayer will form a new limited liability company (the “LLC”) that will be wholly owned by taxpayer and that will be a disregarded entity for federal tax purposes. At closing, 100% of the general partnership interest of LP will be transferred to LLC and 100% of the limited partnership interests in LP will be transferred to Taxpayer. The IRS ruled: | |
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Provided by the Federation of Exchange Accommodators. |