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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.


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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 |

Deborah Fields |

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