Experience Category: 1031

Like-Kind Exchange Principles Applicable to Cryptocurrency

Analysis and qualified advice on potential application of pre-2018 like-kind exchange rules to crypto-to-crypto swaps.  Distinctions between different categories of cryptocurrencies.  Work with outside contractor to develop bespoke software to track high-volume transactions (up to mm’s of transactions) tracing through original cost basis and transferred amounts and values in non-recombinant splitting of transfers with differing historical tax basis.  Consideration of overwhelming reporting requirements for high-volume algorithmic traders and pro and con of need for voluminous paper filing on full range of trades.

Tax Planning for 1031 Partial Exchanges of Strip Mall

Tax planning for distribution of TIC interests and partial 1031 exchanges from certain ownership stakes of strip mall held in tiered partnership structure.  Drafting LLC language and TIC agreement and reviewing transfer and dissolution documents RE: same.

In-Kind Distributions through Tiered Partnerships for 1031 Transactions

Multiple transactions involving in-kind distribution of TIC interests through multiple layers of GP-LP partnerships in order to implement partial and/or parallel 1031 transactions.  Drafting of partnership (LLC) agreement language to account for in-kind distributions, review of TIC agreements and analysis of IRS rules and rulings relating to distribution and later transfer for nonrecognition treatment under S. 1031.
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