close
Share with your friends

IRS announces extensions for section 1031 “like-kind exchange” deadlines (COVID-19)

Notice 2020-23: IRS announces extensions

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.

1000

Related content

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:

  • If the 45-day identification period expires on or after April 1, 2020, and before July 15, 2020—the taxpayer may have until July 15, 2020, to complete the identification; or
  • If the 180-day exchange period expires on or after April 1, 2020, and before July 15, 2020—the taxpayer may have until July 15 2020, to complete the exchange (assuming the due date of the return (including extensions obtained) is not before July 15, 2020).


KPMG observation

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.


For more information, contact a tax professional with KPMG’s Washington National Tax practice:

Holly Belanger | hbelanger@kpmg.com

Deborah Fields | dafields@kpmg.com

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us

 

Want to do business with KPMG?

 

loading image Request for proposal