Notice 2020-23, released by the IRS in the afternoon of April 9, 2020, amplifies and significantly expands the relief previously provided in Notice 2020-18 and Notice 2020-20 in response to the coronavirus (COVID-19) pandemic.
Notice 2020-23 [PDF 102 KB] generally provides taxpayers until July 15, 2020, to perform certain time-sensitive actions—including those listed in Rev. Proc. 2018-58—that were otherwise due to be performed on or after April 1, 2020, and before July 15, 2020.
Compliance with the 45-day identification period and 180-day exchange period in section 1031(a)(3) and Rev. Proc. 2000-37 are time-sensitive actions covered by Rev. Proc. 2018-58 and Notice 2020-23.
Accordingly, taxpayers that have a like-kind exchange currently in process:
Section 17 of Rev. Proc. 2018-58 includes additional relief for like-kind exchange transactions which, if applicable, could extend the timing requirements for certain transactions beyond July 15, 2020. It is unclear whether Notice 2020-23 authorizes this additional relief.
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