IRC §1031 Like-Kind Exchange Guide (2026)

Real Property  •  45-Day Rule  •  180-Day Rule  •  Boot  •  Qualified Intermediary
IRC §1031 Treas. Reg. §1.1031(a)-1 Rev. Proc. 2000-37
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A Section 1031 like-kind exchange allows a real estate investor to defer capital gains tax on the sale of investment or business property by reinvesting the proceeds into another qualifying property. Done correctly, 100% of the gain can be deferred - potentially indefinitely. Done incorrectly, the exchange fails and the full gain becomes taxable in the year of sale.

TCJA Change - Personal Property Excluded Since 2018

The Tax Cuts and Jobs Act (2017) limited §1031 exchanges to real property only, effective January 1, 2018. Vehicles, equipment, aircraft, artwork, collectibles, and other tangible personal property no longer qualify. OBBBA (P.L. 119-21) made no changes to this restriction. Only real property held for productive use in a trade or business or for investment qualifies. IRC §1031(a)(1); IRC §1031(h).

The Four Requirements

All four must be satisfied for a valid §1031 exchange:

RequirementRuleAuthority
Qualifying propertyReal property held for investment or business use. Primary residences do not qualify (unless mixed use). IRC §1031(a)(1).IRC §1031(a)(1); (h)(1)
Like-kind propertyReplacement property must be real property. Any US real property is like-kind to any other US real property - an apartment building is like-kind to raw land, a commercial building to a single-family rental. Foreign property is only like-kind to other foreign property. IRC §1031(h)(2).IRC §1031(a)(1); Treas. Reg. §1.1031(a)-1(b)
45-day identificationReplacement property must be formally identified in writing within 45 days of closing on the relinquished property. No exceptions. If you miss the 45-day deadline, the exchange fails.IRC §1031(a)(3)(A); Treas. Reg. §1.1031(k)-1(b)
180-day closingReplacement property must be acquired by the earlier of: 180 days after closing on the relinquished property, or the due date of your tax return (including extensions) for the year of the exchange. File an extension if necessary to preserve the full 180 days.IRC §1031(a)(3)(B); Treas. Reg. §1.1031(k)-1(b)(2)

The Exchange Timeline

0
Day 0
Close on Relinquished Property
Sale proceeds must go directly to a Qualified Intermediary (QI) - not to you. If proceeds touch your hands or your bank account, the exchange is invalid. The QI holds the funds in escrow. Execute exchange agreement with QI before closing.
45
Day 45 - Hard Deadline
Identification Deadline
Written identification of replacement property must be delivered to the QI (or other designated party) by midnight on Day 45. You may identify up to 3 properties regardless of value (3-property rule), or any number of properties whose total value does not exceed 200% of the relinquished property value (200% rule), or properties that you close on constituting at least 95% of identified value (95% rule). No extensions available - this is a hard deadline under the regulations.
180
Day 180 - Or Tax Return Due Date
Acquisition Deadline
You must close on the replacement property by the earlier of Day 180 or your tax return due date (with extensions). If you sell in 2026 and do not file an extension, your return is due April 15, 2027 - which may be before Day 180 expires. File Form 4868 to extend your return and preserve the full 180 days. The exchange is reported on Form 8824.

Boot - When You Don't Reinvest Everything

Boot is the portion of exchange proceeds not reinvested in like-kind property. Boot is taxable in the year of exchange up to the amount of realized gain. Boot can be cash (you receive cash out of escrow) or mortgage boot (the replacement property has a smaller loan than the relinquished property).

Example - Partial Exchange with Boot
Sale price of relinquished property$800,000
Adjusted basis (original cost minus depreciation)$300,000
Realized gain$500,000
Replacement property purchase price$700,000
Cash boot received (not reinvested)$100,000
Boot recognized (taxable in year of exchange)$100,000
Gain deferred into replacement property$400,000
Federal tax saved at 23.8% (20% LTCG + 3.8% NIIT)~$95,200

Depreciation Recapture - Not Fully Deferred

Depreciation previously claimed on the relinquished property is subject to recapture under IRC §1250, taxed at up to 25% ordinary income rates. §1031 defers the capital gain but does not eliminate depreciation recapture. The recaptured depreciation carries over into the replacement property's basis and will be subject to recapture again when the replacement property is eventually sold (unless another §1031 exchange is done).

Qualified Intermediary - The Most Critical Element

A Qualified Intermediary (QI) is required for all delayed exchanges (where sale and purchase of replacement property do not happen simultaneously). The QI is an independent third party who holds the exchange proceeds, executes the exchange agreement, and transfers the funds to purchase the replacement property. The taxpayer cannot have actual or constructive receipt of the funds during the exchange period.

QI failure risk: Several large qualified intermediary companies have gone bankrupt while holding exchange funds, resulting in significant losses for investors. Choose a QI that: maintains exchange funds in separate FDIC-insured accounts segregated from operating accounts, carries adequate errors and omissions insurance, and has been in business for multiple years. There is no federal licensing requirement for QIs.

Special Exchange Types

Reverse Exchange

A reverse exchange allows you to acquire the replacement property before selling the relinquished property. The replacement property must be acquired through an Exchange Accommodation Titleholder (EAT) - typically an LLC controlled by the QI - who holds legal title until the relinquished property is sold. The same 45-day and 180-day rules apply, running from the date the EAT acquires the replacement property. Rev. Proc. 2000-37.

Build-to-Suit (Improvement) Exchange

Allows exchange proceeds to be used for construction or improvements on the replacement property, provided the improvements are complete and the property is received with the enhanced value within the 180-day period. Improvements made after the 180-day deadline do not count toward satisfying the exchange. Treas. Reg. §1.1031(k)-1(e).

What Disqualifies an Exchange

Disqualifying EventResult
Proceeds touch taxpayer's hands before exchange completesFull gain recognized in year of sale
Identification not made by Day 45Exchange fails; full gain recognized
Replacement property not acquired by Day 180Exchange fails; full gain recognized
Replacement property is personal property (not real estate)That property does not qualify; gain on that portion recognized
Primary residence (personal use) exchangedDoes not qualify; consider IRC §121 exclusion instead
Related party exchange and replacement property sold within 2 yearsGain on original exchange recognized at time of related party sale; IRC §1031(f)

Basis in Replacement Property

The adjusted basis of the replacement property equals: fair market value of the replacement property, minus the gain deferred in the exchange. This means the deferred gain reduces the tax basis - creating lower depreciation deductions going forward and higher gain on a future sale. The tax deferral is not elimination. When the replacement property is eventually sold in a taxable transaction (not another §1031), all deferred gains from prior exchanges become taxable at that time. IRC §1031(d).

Authority: IRC §1031 (like-kind exchanges); IRC §1031(a)(1) (qualifying property); IRC §1031(a)(3) (identification and exchange periods); IRC §1031(d) (basis); IRC §1031(f) (related party rules); IRC §1031(h) (real property only, post-TCJA); IRC §1250 (depreciation recapture); Treas. Reg. §1.1031(a)-1; Treas. Reg. §1.1031(k)-1 (deferred exchanges); Rev. Proc. 2000-37 (reverse exchanges); Form 8824 (reporting like-kind exchanges); OBBBA (P.L. 119-21) (no changes to §1031).
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