CCH Federal Taxation Basic Principles
48 of 66
Techniques involving leasehold interests, options to purchase, or qualified intermediaries may be used to avoid the reverse-Starker problem.
Rev. Proc. 2000-37 creates a safe harbor for certain post-September 14, 2000 reverse Starker transactions. This involves “parking” the properties to be exchanged with an “exchange accommodation titleholder’ until a qualified exchange can occur.
Like-Kind Exchanges—Avoiding Reverse Starkers
Chapter 11, Exhibit 13d