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In-Kind Distributions through Tiered Partnerships for 1031 Transactions

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.