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Apr 15, 2008Vacation Homes Can Now Qualify for Like-Kind Treatment

A second home may serve as a vacation escape, a rental property or both.  If you are planning to sell a second home in the near future, there is a new tax development to consider.

Generally, the Internal Revenue Service allows for any gain from the sale or exchange of property held for productive use in a business or for investment to be deferred if all of the proceeds are re-invested in "like-kind" property within 180 days of the sale or exchange.  In the past this favorable treatment did not apply to personal residences that were not rented.  In Revenue Procedure 2008-16 which was released in February 2008, the IRS provided guidance whereby a "dwelling unit" will now qualify for this favorable treatment if certain conditions exist, which will now allow more taxpayers to benefit from this opportunity when selling a vacation home.

A dwelling unit is defined to include real property improved with a house, apartment, condominium or similar improvement that provides basic living accommodations including sleeping space, bathroom and cooking facilities.

In order to qualify for this favorable tax reporting position, several requirements apply:

  • Period of ownership of the property must be at least 24 months immediately before the sale
  • In each of two twelve month periods immediately before the sale, the taxpayer must have rented the unit to another person at a fair market rental for fourteen days or more and cannot have used it personally for the greater of fourteen days or ten percent of the number of days it was rented at a fair rental
  • The replacement property must meet the same standards as listed above for the property sold


Let's assume a taxpayer acquired an oceanfront vacation residence ten years ago for $750,000 and is planning to sell the property in two years for $1,500,000.  If the taxpayer is subject to a combined federal and state rate of 20%, $150,000 will be due.  However, if the taxpayer reduced their personal use of the property as outlined above and reinvested the proceeds in "like-kind" property, they could eliminate all of the $150,000 of taxes related to the sale in the current year.

If the taxpayer fails the tests related to the replacement property after reporting the transaction as a qualified "like-kind" exchange, they must amend their prior return and report the gain.

If you are planning a property sale or purchase, utilizing a like-kind exchange could result in significant tax savings.  For more information, contact Dwayne Holt or your Beers + Cutler partner.

 

 

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