A Review of Tax-Free Exchanges of Partnership Interests: Are They Still Possible?

Author

Sandra K. Becker, Fontbonne College

Year of Award

1992

Degree

Master of Science in Taxation (MST)

College

College of Business & Professional Studies

Degree Program

Taxation

Department

Business Administration

Keywords

exchange, estate, taxes, reform

Abstract

The topic I chose for my Capstone Research Project is "A Review Of Tax-Free Exchanges Of Partnership Interests - Are They Still Possible?". I find this topic of particular interest since much of today’s real estate is held by partnerships; and when disposing of real property, many investors wish to utilize the benefits of a tax-free exchange. Current provisions of Section 1031 specifically exclude exchanges of partnership interests from tax-free treatment. This disallowance creates a great injustice for property owners whose property is held by partnerships.

This paper reviews prior and current law concerning exchanges of partnership interests and focuses primarily on the key tax issues involved in exchanging property formerly held by corporations and partnerships. Some of the major cases and rulings are analyzed and an alternative technique is proposed that allows partners an opportunity to take advantage of the tax-free provisions of Section 1031.

Document Type

Restricted Thesis

Recommended Citation

Becker, Sandra K., "A Review of Tax-Free Exchanges of Partnership Interests: Are They Still Possible?" (1992). All Theses, Dissertations, and Capstone Projects. 372.
https://griffinshare.fontbonne.edu/all-etds/372