Service Issues Favorable Private Letter Ruling On Reverse Parking Exchange Transaction Involving Multiple Related Parties

Service Issues Favorable Private Letter Ruling On Reverse Parking Exchange Transaction Involving Multiple Related Parties

In PLR 201416006 (4/18/2014)  the Service ruled that a taxpayer could successfully effectuate a reverse like-kind exchange under §1031, and in accordance with the safe harbor guidance issued in  Rev. Proc. 2000-37, 2000-2 C.B. 308,  even though the taxpayer and two related parties entered into a separate qualified exchange accommodation arrangements (QEAAs) for “parking” the same property held by an exchange accommodation titleholder (EATX).