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IRS Rules Transferable Development Rights Are Real Property for Section 1031 Purposes

By Josh Prywes & Shivani Rumalla on September 15, 2023
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A new Internal Revenue Service (IRS) Private Letter Ruling says that transferable development rights (TDRs) are of “like kind” with tangible real property and eligible for 1031 tax deferred treatment, even though these rights are intangible rights related to real property. The IRS issued Private Letter Ruling 202335002 (the PLR) regarding whether TDRs are of “like kind” within the meaning of Section 1031 of the Internal Revenue Code.

Continue reading the full GT Alert.

Photo of Josh Prywes Josh Prywes

Josh Prywes focuses his practice on federal, international, multistate, and local tax planning and implementation for both U.S. and foreign companies. Josh also has experience representing investors and developers in real estate joint venture agreements and related development agreements. Josh has advised a…

Josh Prywes focuses his practice on federal, international, multistate, and local tax planning and implementation for both U.S. and foreign companies. Josh also has experience representing investors and developers in real estate joint venture agreements and related development agreements. Josh has advised a variety of businesses on the tax implications of inbound and outbound transactions. He regularly structures and negotiates complex partnership and corporate agreements throughout the United States and has experience advising clients on the tax implications of real estate transactions and corporate mergers and acquisitions.

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Photo of Shivani Rumalla Shivani Rumalla

Shivani Rumalla focuses her practice on federal, international, multistate, and local tax planning and implementation for both U.S. and foreign companies. She regularly structures, drafts, and negotiates complex joint ventures throughout the United States and has experience advising clients on tax efficient structuring…

Shivani Rumalla focuses her practice on federal, international, multistate, and local tax planning and implementation for both U.S. and foreign companies. She regularly structures, drafts, and negotiates complex joint ventures throughout the United States and has experience advising clients on tax efficient structuring of real estate transactions, REIT formations, and corporate mergers and acquisitions. Shivani’s tax experience also includes advising a variety of businesses on the tax implications of inbound and outbound transactions, advising clients on the tax implications of a bankruptcy filing, and representing clients in federal tax controversy matters.

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  • Posted in:
    Tax
  • Blog:
    Legacy Advisors
  • Organization:
    Greenberg Traurig, LLP

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