14 Apr 2020 Extensions for Tax-Free Section 1031 Deadlines
Notice 2020-23 (which updates Notice 2020-18, “Additional Relief for Taxpayers Affected by Ongoing Coronavirus Disease 2019 Pandemic”), released on April 9, 2020, provides Taxpayers who are currently engaged in a 1031 exchange some relief from the 45-Day Identification and 180-Day Exchange Period deadlines.
The notice provides that any person performing a time-sensitive action which is due to be performed on or after April 1, 2020, and before July 15, is an Affected Taxpayer.
The Notice states that “Affected Taxpayers also have until July 15, 2020, to perform all Specified Time Sensitive Actions, that are due to be performed on or after April 1, 2020, and before July 15, 2020.” This appears to provide that any Affected Taxpayer with a 45-Day Exchange Period or 180-Day Exchange Period deadline between April 1 and July 15, 2020 will have an automatic extension to July 15, 2020.
Examples:
- If your identification period falls between 4/1/2020 and 7/15/2020 you have until 7/15/2020 to identify prospective replacement properties.
- If your 180 deadline falls between 4/1/2020 and 7/15/2020 you have until 7/15/2020 to complete your exchange transaction.