Overview


April 10, 2020
--San Diego, California--Exeter 1031 Exchange Services, LLC announced today that the U.S. Treasury (Internal Revenue Service) issued Notice 2020-23 late Thursday evening, April 9, 2020, granting relief to investors that are in the middle of a 1031 Exchange transaction.

This Notice is very different from the typical disaster declaration and extensions granted in the past and is somewhat confusing based upon the way it was drafted. Historically, the President would declare a Natural Disaster for a specific geographic area and a date specific event and the U.S. Treasury (Internal Revenue Service) would then issue a Disaster Relief Notice providing a 120-calendar day extension to the 45- and 180-calendar day deadlines.  This approach was not used this time.

IRS Notice 2020-23

Notice 2020-23, which revises Notice 2020-18, 2020-15 IRB 590 (April 6, 2020), and Notice 2020-20, 2020-16 IRB 660 (April 13, 2020), does not specifically address Section 17 contained within Revenue Procedure 2018-58, so it would initially appear that the 120-calendar day extension is not applicable to the current situation.

Affected Taxpayer (Investor)

The Notice provides that any person performing a time-sensitive action listed in either Section 301.7508A-1(c)(1)(iv) – (vi) of the Procedure and Administration Regulations or Revenue Procedure 2018-58, 2018-50 IRB 990 (December 10, 2018), which is due to be performed on or after April 1, 2020, and on or before July 15, 2020 (Specified Time-Sensitive Action), is an Affected Taxpayer.

Deadline Extension

Therefore, the guidance provided within Notice 2020-23 applies to investors that have a 45-calendar day identification deadline or a 180-calendar day exchange deadline that falls on or after April 1st, 2020 and on or before July 15th, 2020. The applicable deadline that falls within those timelines is extended to July 15th, 2020.

Exeter 1031 Exchange Services, LLC will continue to monitor the current situation and communicate any new guidance from the U.S. Treasury (Internal Revenue Service).  Check the Exeter News Wire for the most recent information and updates.

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This Exeter News Wire is not intended to serve as legal, tax or financial advice.  Exeter 1031 Exchange Services, LLC and Exeter Trust Company do not provide legal, tax or financial advice and make no express or implied warranty respecting the information presented herein and assumes no responsibility or liability for errors or omissions contained herein. You should consult with your own legal, tax and financial advisors regarding your specific real estate transaction or income tax circumstance.

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We Have Answers.  Go Ahead, Ask.

Exeter 1031 Exchange Services, LLC is a leading national provider of Qualified Intermediary, Exchange Accommodation Titleholding, and advisory and consultative 1031 Exchange Services for individual, corporate and institutional clients throughout the United States and the world.  Exeter administers all types of 1031 Exchange transactions, including Forward, Reverse and Improvement (Build-To-Suit or Construction) 1031 Exchange structures, for domestic and foreign real estate transactions. 

Exeter 1031 Exchange Services, LLC currently has regional offices in San Diego, Newport Beach, Los Angeles, and San Francisco, California; Chicago, Illinois; Seattle, Washington; Phoenix, Arizona; Cheyenne, Wyoming; and Ft. Lauderdale, Florida.  You can contact Exeter at anytime, 24 hours a day, 7 days a week, 365 days a year.  Call Exeter 24/7 provides round-the-clock access to our senior 1031 Exchange advisors when you need them.

 

 

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