COVID-19 — IRC Sect 1031 — Timeline Extensions

On Thursday, April 9th the IRS published the IRS published Notice 2020-23 issuing gudiance granting deadline relief for 1031 Exchanges.  The Notice from the IRS leaves some issus unclear, but we have summarized key facts below:

Who Qualifies?

  • Anyone that sold relinquished property and their 45-day deadline falls between April 1st and July 15th.
  • Anyone that sold relinquished property and their 180-day deadline falls between April 1st and July 15th.

What is the Extension?

  • The 45-day deadline has been extended to July 15th.
  • The 180-day deadline has been extended to July 15th.

Examples

  • Taxpayer Bob sold his property on March 1st.  His day 45 deadline of 4/15 is now extended to 7/15.
  • Taxpayer Sue sold her property on October 4, 2019.  Her day 180 of 4/1/2020 is now extended to 7/15/2020.  She does not have an extension for her day 45.

It is unclear if this will be the final guidance that the IRS issues related to 1031 Exchange deadlines.