
1031 Rules
The “Like-Kind” Requirement
In order to qualify for safe harbor tax deferral, the Relinquished Property must be “like-kind” to the Replacement Property. It is this “like-kind” definition that often confuses many taxpayers and their tax advisors.
In exchange transactions involving real property, all real property is deemed to be “like-kind” with other real property. Thus, as an example, a retail shopping center is “like-kind” to an office building while raw land is “like-kind” to an apartment building. Also qualifying as “like-kind” real property:
- Raw Land
- Office Buildings
- Retail Property
- Multi-family property
- Residential rental property
- Leases and Lease Options of 30+ years
- Options and Contracts
- Oil, Gas and Mineral Rights
- Tenants-in-Common (“TIC”) Interests
- Boat Slips/Docks
(note that state law will control whether these are treated as personal property or real property)
In personal property exchanges, the “like-kind” requirement is much more restrictive and therefore more onerous for the taxpayer. As an example, an aircraft is not “like-kind” to a bulldozer, and a car is not “like-kind” to a truck.
Property Identification Rules
There are three different rules that an exchanger can utilize when identifying
property
in a 1031 exchange:
1. The Three Property Rule: The Exchanger may identify up to three potential Replacement Properties without regard to their value.
Or
2. The 200% Rule:The Exchanger may identify more than three properties, provided that the aggregate fair market value of these properties does not exceed 200% of the value of the Relinquished Property.
Or
3. The 95% Rule: The Exchanger may identify more than three properties, without regard to their aggregate value, provided that the Exchanger acquires 95% of the fair market value of the identified properties.

