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Like-kind exchange

Aircraft used for business and personal use is single property for like-kind qualification purposes

Aircraft used for business and personal use is single property for like-kind qualification purposes

Chief Counsel Advice 201605017 In Chief Counsel Advice involving an exchange of two aircrafts intended to qualify under Code Sec. 1031, one of which was used by an individual for personal purposes as well as for productive use in a trade or business or investment, IRS determined that the aircraft was a single property, the […]

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Exchange of rights to manufacture and/or distribute products was like-kind exchange

Exchange of rights to manufacture and/or distribute products was like-kind exchange

PLR 201531009 In a private letter ruling, IRS has held that a taxpayer’s exchange of certain manufacturing and/or distribution rights with respect to a given group of products, for other manufacturing and/or distribution rights with respect to that same group of products, was a like-kind exchange with no recognition of gain or loss. Background. Code Sec. […]

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Eighth Circuit: no like-kind exchange treatment in related party transaction

Eighth Circuit: no like-kind exchange treatment in related party transaction

North Central Rental & Leasing, (CA8 3/2/2015) 115 AFTR 2d ¶ 2015-494   The Court of Appeals for the Eighth Circuit has affirmed a District Court decision that a taxpayer could not avoid the Code Sec. 1031(f) like-kind exchange related-party rule by interposing unnecessary parties into the exchange transactions. The Eighth Circuit found that the […]

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IRS OKs like-kind exchange program participant’s replacement property substitution

IRS OKs like-kind exchange program participant’s replacement property substitution

PLR 201437012 In a Technical Advice Memorandum (TAM), IRS’s National Office has found that, where a taxpayer met the requirements for coverage under Rev Proc 2003-39’s “like-kind exchange program” (LKE Program) for taxpayers who continuously engage in like-kind exchanges, and it entered into a transaction in which it substituted a second property for ineligible replacement […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney