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  • How to Choose a Qualified Intermediary for your 1031 Exchange

    There is an old adage that states “Just because you can do something-doesn’t mean you should.” This sage advice certainly applies to choosing a qualified intermediary to facilitate a 1031 like-kind exchange. The use of a qualified intermediary is essential to completing a successful 1031 exchange because, while the process of completing an exchange is straightforward, the rules are complicated and loaded with potential pitfalls for the exchanger if the exchange is not properly prepared.
    To simplify the discussion and underscore the potential challenges of selecting a qualified intermediary, let’s identify parties who cannot act as a qualified intermediary. This list is relatively short and essentially disqualifies those who have acted in some advisory capacity for your company during the two years prior to a potential exchange:

    Related Parties – Including certain family members and business entities with shared/common ownership.
    Agents – Including individuals that have provided services to the exchanging taxpayer as an employee, attorney, accountant, investment banker or broker within the two year period ending on the date of the transfer of the first of the relinquished properties.

    Aside from the above, virtually anyone can legally act in the capacity of a qualified intermediary, and therein lies the potential for disaster.
    I spoke about 1031 exchanges recently at a conference where one of the attendees, an equipment dealer who had advised a customer on their like-kind exchange, stated his belief that the only requirement for a qualified intermediary was that they be a third party who could hold the money from the sale of the relinquished equipment until the seller requires the money for the purchase of replacement property.
    While it’s true that any third party can legally provide the service outlined above, they’ll likely fall short of providing a properly-structured 1031 exchange that satisfies the Internal Revenue Service’s safe harbor guidelines. I inquired further:

    Did the selling party execute an Exchange Agreement outlining the safe harbor compliance rules? Without specific restrictions on the sales proceeds contained in this agreement, the exchanger still has constructive receipt of funds from the sale.
    Did the third party create a separate bank account for the specific benefit of the seller/exchanger during the exchange period?
    Did the seller notify the buyer that they had assigned their interests and rights in the sold equipment to the qualified intermediary?
    Did your customer notify the seller that he had assigned his interests and rights in the new equipment to the qualified intermediary?
    Did your customer send a Replacement Property Identification Notice to the qualified intermediary before the expiration of the identification period, identifying the equipment the buyer planned on purchasing by one of the two approved methods?
    Did you (the equipment store) notify the customer that he had 45 days to identify potential replacement equipment and up to 180 days from the sale of the used equipment to purchase the new replacement equipment?
    Did you provide all of the documentation and signatures required by the Treasury to ensure that the seller indeed satisfied the IRC safe harbor compliance rules and regulations?

    When the color returned to his face and the nausea had passed, the equipment dealer uttered the far too common response of someone who had purported to serve as a qualified intermediary but was not one.  “All we did was hold the money and then forward it to the seller when it came time to buy.”
    Like-kind exchanges offer sellers of used equipment a tremendous opportunity to reinvest in funds that would otherwise be lost to taxes, but in order to enjoy this benefit exchangers must follow a document and deadline driven process. When engaging a qualified intermediary, be certain that they understand the necessary documents, steps, and safe harbors that are inherent in Section 1031. Doing so will result in a properly-structured and secure exchange.
    https://info.accruit.com/start-an-exchange”>

     
     
     

  • How to Choose a Qualified Intermediary for your 1031 Exchange

    There is an old adage that states “Just because you can do something-doesn’t mean you should.” This sage advice certainly applies to choosing a qualified intermediary to facilitate a 1031 like-kind exchange. The use of a qualified intermediary is essential to completing a successful 1031 exchange because, while the process of completing an exchange is straightforward, the rules are complicated and loaded with potential pitfalls for the exchanger if the exchange is not properly prepared.
    To simplify the discussion and underscore the potential challenges of selecting a qualified intermediary, let’s identify parties who cannot act as a qualified intermediary. This list is relatively short and essentially disqualifies those who have acted in some advisory capacity for your company during the two years prior to a potential exchange:

    Related Parties – Including certain family members and business entities with shared/common ownership.
    Agents – Including individuals that have provided services to the exchanging taxpayer as an employee, attorney, accountant, investment banker or broker within the two year period ending on the date of the transfer of the first of the relinquished properties.

    Aside from the above, virtually anyone can legally act in the capacity of a qualified intermediary, and therein lies the potential for disaster.
    I spoke about 1031 exchanges recently at a conference where one of the attendees, an equipment dealer who had advised a customer on their like-kind exchange, stated his belief that the only requirement for a qualified intermediary was that they be a third party who could hold the money from the sale of the relinquished equipment until the seller requires the money for the purchase of replacement property.
    While it’s true that any third party can legally provide the service outlined above, they’ll likely fall short of providing a properly-structured 1031 exchange that satisfies the Internal Revenue Service’s safe harbor guidelines. I inquired further:

    Did the selling party execute an Exchange Agreement outlining the safe harbor compliance rules? Without specific restrictions on the sales proceeds contained in this agreement, the exchanger still has constructive receipt of funds from the sale.
    Did the third party create a separate bank account for the specific benefit of the seller/exchanger during the exchange period?
    Did the seller notify the buyer that they had assigned their interests and rights in the sold equipment to the qualified intermediary?
    Did your customer notify the seller that he had assigned his interests and rights in the new equipment to the qualified intermediary?
    Did your customer send a Replacement Property Identification Notice to the qualified intermediary before the expiration of the identification period, identifying the equipment the buyer planned on purchasing by one of the two approved methods?
    Did you (the equipment store) notify the customer that he had 45 days to identify potential replacement equipment and up to 180 days from the sale of the used equipment to purchase the new replacement equipment?
    Did you provide all of the documentation and signatures required by the Treasury to ensure that the seller indeed satisfied the IRC safe harbor compliance rules and regulations?

    When the color returned to his face and the nausea had passed, the equipment dealer uttered the far too common response of someone who had purported to serve as a qualified intermediary but was not one.  “All we did was hold the money and then forward it to the seller when it came time to buy.”
    Like-kind exchanges offer sellers of used equipment a tremendous opportunity to reinvest in funds that would otherwise be lost to taxes, but in order to enjoy this benefit exchangers must follow a document and deadline driven process. When engaging a qualified intermediary, be certain that they understand the necessary documents, steps, and safe harbors that are inherent in Section 1031. Doing so will result in a properly-structured and secure exchange.
    https://info.accruit.com/start-an-exchange”>

     
     
     

  • 1031 Like-Kind Exchange Fallacies

    1031 like-kind exchanges or tax deferred exchanges have been part of the United States tax code since 1921, yet they continue to be the subject of a number of misconceptions, some of which are addressed below.
    Fallacy: 1031 like-kind exchanges are only for the wealthy.
    This misconception arises from the visibility that high-profile companies or individuals have when exchanging an office building or a rental property and deferring the tax on the sale of that asset. What is being missed is that average everyday people are utilizing like-kind exchanges as well.
    An individual who defers tax on selling a small rental property when she buys a replacement property is taking advantage of Section 1031 of the tax code. These sorts of transactions made by small businesses and middle-class investors are frequent, even if they don’t make the headlines.
    I had the opportunity to meet a mechanic recently in Phoenix, Arizona who, upon learning about our company, related his own like-kind exchange story. He had purchased a rental home four years ago for a terrific price, and when the market went up, he was able to enter into a contract to sell it for a profit. He was lucky to have a smart accountant who advised him to structure the transaction as an exchange with a qualified intermediary enabling him to reinvest all of the proceeds in another rental, thereby deferring tax on the sale. He did so and has now profited enough to secure a down payment on three rental properties, about which he remarked, “On a mechanics salary, without 1031s I would never have been able to own three rentals.”
    Fallacy: A 1031 exchange must be simultaneous.
    The most common type of 1031 exchange is a forward exchange, in which the proceeds from the sale of one asset is used to purchase an asset considered to be like-kind within 180 days.
    There are other 1031 exchange deadlines, but the 180-day completion period allows for non-simultaneous exchanges. It is even possible, in a reverse exchange, to purchase replacement property up to 180 days prior to selling the relinquished property.
    Fallacy: The Relinquished Property must be the exact same as the Replacement Property in order to be “like-kind.”
    In real estate, the term “like-kind” is remarkably broad. Most real estate property is considered “like-kind.” Land can exchange into an office building; a rental home can exchange into a Delaware Statutory Trust (DST); a multi-family complex can exchange into twenty rental homes. The list could go on, but the point is that there are many options in real estate when doing an exchange.
    Fallacy: 1031 exchanges are a tax loophole.
    Congress established 1031 like-kind exchanges as part of the Internal Revenue Code in 1921 with two primary purposes:

    To avoid unfair taxation of ongoing investments
    To encourage active reinvestment

    Nearly 100 years later, like-kind exchanges continue to support sales and purchases of real estate and business assets, encourage business expansion, and stimulate economic growth. They are an intentional and integral aspect of United States tax law, not a tax avoidance strategy.
    Conclusion
    Clearing up the misconceptions about what 1031 like-kind exchanges are and how they work continues to be part of Accruit’s mission, since the first step to employing like-kind exchanges is understanding them. If there’s any audience to whom the use of 1031s is limited, it’s the informed.

  • 1031 Like-Kind Exchange Fallacies

    1031 like-kind exchanges or tax deferred exchanges have been part of the United States tax code since 1921, yet they continue to be the subject of a number of misconceptions, some of which are addressed below.
    Fallacy: 1031 like-kind exchanges are only for the wealthy.
    This misconception arises from the visibility that high-profile companies or individuals have when exchanging an office building or a rental property and deferring the tax on the sale of that asset. What is being missed is that average everyday people are utilizing like-kind exchanges as well.
    An individual who defers tax on selling a small rental property when she buys a replacement property is taking advantage of Section 1031 of the tax code. These sorts of transactions made by small businesses and middle-class investors are frequent, even if they don’t make the headlines.
    I had the opportunity to meet a mechanic recently in Phoenix, Arizona who, upon learning about our company, related his own like-kind exchange story. He had purchased a rental home four years ago for a terrific price, and when the market went up, he was able to enter into a contract to sell it for a profit. He was lucky to have a smart accountant who advised him to structure the transaction as an exchange with a qualified intermediary enabling him to reinvest all of the proceeds in another rental, thereby deferring tax on the sale. He did so and has now profited enough to secure a down payment on three rental properties, about which he remarked, “On a mechanics salary, without 1031s I would never have been able to own three rentals.”
    Fallacy: A 1031 exchange must be simultaneous.
    The most common type of 1031 exchange is a forward exchange, in which the proceeds from the sale of one asset is used to purchase an asset considered to be like-kind within 180 days.
    There are other 1031 exchange deadlines, but the 180-day completion period allows for non-simultaneous exchanges. It is even possible, in a reverse exchange, to purchase replacement property up to 180 days prior to selling the relinquished property.
    Fallacy: The Relinquished Property must be the exact same as the Replacement Property in order to be “like-kind.”
    In real estate, the term “like-kind” is remarkably broad. Most real estate property is considered “like-kind.” Land can exchange into an office building; a rental home can exchange into a Delaware Statutory Trust (DST); a multi-family complex can exchange into twenty rental homes. The list could go on, but the point is that there are many options in real estate when doing an exchange.
    Fallacy: 1031 exchanges are a tax loophole.
    Congress established 1031 like-kind exchanges as part of the Internal Revenue Code in 1921 with two primary purposes:

    To avoid unfair taxation of ongoing investments
    To encourage active reinvestment

    Nearly 100 years later, like-kind exchanges continue to support sales and purchases of real estate and business assets, encourage business expansion, and stimulate economic growth. They are an intentional and integral aspect of United States tax law, not a tax avoidance strategy.
    Conclusion
    Clearing up the misconceptions about what 1031 like-kind exchanges are and how they work continues to be part of Accruit’s mission, since the first step to employing like-kind exchanges is understanding them. If there’s any audience to whom the use of 1031s is limited, it’s the informed.

  • 1031 Like-Kind Exchange Fallacies

    1031 like-kind exchanges or tax deferred exchanges have been part of the United States tax code since 1921, yet they continue to be the subject of a number of misconceptions, some of which are addressed below.
    Fallacy: 1031 like-kind exchanges are only for the wealthy.
    This misconception arises from the visibility that high-profile companies or individuals have when exchanging an office building or a rental property and deferring the tax on the sale of that asset. What is being missed is that average everyday people are utilizing like-kind exchanges as well.
    An individual who defers tax on selling a small rental property when she buys a replacement property is taking advantage of Section 1031 of the tax code. These sorts of transactions made by small businesses and middle-class investors are frequent, even if they don’t make the headlines.
    I had the opportunity to meet a mechanic recently in Phoenix, Arizona who, upon learning about our company, related his own like-kind exchange story. He had purchased a rental home four years ago for a terrific price, and when the market went up, he was able to enter into a contract to sell it for a profit. He was lucky to have a smart accountant who advised him to structure the transaction as an exchange with a qualified intermediary enabling him to reinvest all of the proceeds in another rental, thereby deferring tax on the sale. He did so and has now profited enough to secure a down payment on three rental properties, about which he remarked, “On a mechanics salary, without 1031s I would never have been able to own three rentals.”
    Fallacy: A 1031 exchange must be simultaneous.
    The most common type of 1031 exchange is a forward exchange, in which the proceeds from the sale of one asset is used to purchase an asset considered to be like-kind within 180 days.
    There are other 1031 exchange deadlines, but the 180-day completion period allows for non-simultaneous exchanges. It is even possible, in a reverse exchange, to purchase replacement property up to 180 days prior to selling the relinquished property.
    Fallacy: The Relinquished Property must be the exact same as the Replacement Property in order to be “like-kind.”
    In real estate, the term “like-kind” is remarkably broad. Most real estate property is considered “like-kind.” Land can exchange into an office building; a rental home can exchange into a Delaware Statutory Trust (DST); a multi-family complex can exchange into twenty rental homes. The list could go on, but the point is that there are many options in real estate when doing an exchange.
    Fallacy: 1031 exchanges are a tax loophole.
    Congress established 1031 like-kind exchanges as part of the Internal Revenue Code in 1921 with two primary purposes:

    To avoid unfair taxation of ongoing investments
    To encourage active reinvestment

    Nearly 100 years later, like-kind exchanges continue to support sales and purchases of real estate and business assets, encourage business expansion, and stimulate economic growth. They are an intentional and integral aspect of United States tax law, not a tax avoidance strategy.
    Conclusion
    Clearing up the misconceptions about what 1031 like-kind exchanges are and how they work continues to be part of Accruit’s mission, since the first step to employing like-kind exchanges is understanding them. If there’s any audience to whom the use of 1031s is limited, it’s the informed.

  • Fractional Ownership of Real Estate

    There are many benefits to owning real estate – appreciation, diversification, mortgage interest deduction, and 1031 tax deferment are a few. However, not everyone has the capital to purchase high-end properties like a Donald Trump. Because of the high cost of real estate, many investors seek out angel funding and bank loans to make up their capital shortfalls. Yet, there is another way for an investor to own real estate, and that is fractional ownership. Fractional ownership is an investment structure that allows multiple investors to purchase a percentage ownership in an investment-grade asset.
    Benefits of Fractional Ownership of Real Estate
    Diversification
    Fractional ownership, formerly the province of the savvy mogul who has built a career owning, operating, leasing, and selling real estate, has attracted individual investors who seek an alternative investment to stocks, bonds, and mutual funds they may already own. Fractional real estate ownership and other alternative investments provide for diversification, and financial advisors will often dedicate 10% of a clients’ portfolio towards such vehicles.
    The 3 T’s of Real Estate
    Fractional ownership can be very attractive to real estate investors who wish to unburden themselves of real estate’s 3 T’s (tenants, toilets, and trash). The day-to-day realities of owning real estate – grounds maintenance, property up-keep, and leasing – are not an issue for fractional owners. Investors can enjoy all the benefits of a solid return while not laboring over the 3 T’s.
    Options for Fractional Ownership of Real Estate
    In the United States, there are two primary options for those interested in fractional real estate ownership:  Delaware Statutory Trust (DST) and Tenant-In-Common (TIC) ownership. Each option has become increasingly popular as an alternative investment over the past decade because each affords opportunities for individual investors to own investment-grade property – commercial real estate with more income-generating potential than smaller residential property.
    Tenant-in-Common (TICs)
    Tenant-in-common (TIC) is an investment property structure that was established during the 1990s and has grown in popularity since. Think of a TIC as a form of shared tenure rights to properties owned.  Tenants-in-common each own a separate interest in the same real property. The advantages of a TIC are that each tenant-in-common has stronger buying power and fewer costs, and that each shares responsibilities for a property that is owned by the partnership. 
    Delaware Statutory Trusts (DSTs)
    DSTs are legal entities created as trusts within the state of Delaware in which each investor owns a “beneficial interest” in the DST. DSTs have gained popularity over the last few years due to the ability to secure financing and attract more investors with lower minimum investment thresholds. Another advantage of a DST is that a lender underwrites a single borrower, as opposed to the multiple borrowers within the TIC structure. Furthermore, there is no stated IRS limit to the number of investors a DST may have, versus the 35 maximum of the TIC.  Consequently, larger properties may be purchased while keeping the minimum investment size to around $100,000.  Finally, DSTs do not allow for any input from beneficial interest owners, unlike TICs, which need to get unanimous approval from all TIC members.
    Jokingly, a wise man once told me that a DST is the “Arnold Schwarzenegger version of a TIC.”
    Conclusion
    DSTs and TICs afford individual investors entry into large commercial property, either through a cash investment (typically $100,000 and up) or a 1031 exchange of real assets. Before investing in a DST or TIC, be certain to research the property and the company sponsoring the DST or TIC, and engage a qualified intermediary for your like-kind exchange.

  • Fractional Ownership of Real Estate

    There are many benefits to owning real estate – appreciation, diversification, mortgage interest deduction, and 1031 tax deferment are a few. However, not everyone has the capital to purchase high-end properties like a Donald Trump. Because of the high cost of real estate, many investors seek out angel funding and bank loans to make up their capital shortfalls. Yet, there is another way for an investor to own real estate, and that is fractional ownership. Fractional ownership is an investment structure that allows multiple investors to purchase a percentage ownership in an investment-grade asset.
    Benefits of Fractional Ownership of Real Estate
    Diversification
    Fractional ownership, formerly the province of the savvy mogul who has built a career owning, operating, leasing, and selling real estate, has attracted individual investors who seek an alternative investment to stocks, bonds, and mutual funds they may already own. Fractional real estate ownership and other alternative investments provide for diversification, and financial advisors will often dedicate 10% of a clients’ portfolio towards such vehicles.
    The 3 T’s of Real Estate
    Fractional ownership can be very attractive to real estate investors who wish to unburden themselves of real estate’s 3 T’s (tenants, toilets, and trash). The day-to-day realities of owning real estate – grounds maintenance, property up-keep, and leasing – are not an issue for fractional owners. Investors can enjoy all the benefits of a solid return while not laboring over the 3 T’s.
    Options for Fractional Ownership of Real Estate
    In the United States, there are two primary options for those interested in fractional real estate ownership:  Delaware Statutory Trust (DST) and Tenant-In-Common (TIC) ownership. Each option has become increasingly popular as an alternative investment over the past decade because each affords opportunities for individual investors to own investment-grade property – commercial real estate with more income-generating potential than smaller residential property.
    Tenant-in-Common (TICs)
    Tenant-in-common (TIC) is an investment property structure that was established during the 1990s and has grown in popularity since. Think of a TIC as a form of shared tenure rights to properties owned.  Tenants-in-common each own a separate interest in the same real property. The advantages of a TIC are that each tenant-in-common has stronger buying power and fewer costs, and that each shares responsibilities for a property that is owned by the partnership. 
    Delaware Statutory Trusts (DSTs)
    DSTs are legal entities created as trusts within the state of Delaware in which each investor owns a “beneficial interest” in the DST. DSTs have gained popularity over the last few years due to the ability to secure financing and attract more investors with lower minimum investment thresholds. Another advantage of a DST is that a lender underwrites a single borrower, as opposed to the multiple borrowers within the TIC structure. Furthermore, there is no stated IRS limit to the number of investors a DST may have, versus the 35 maximum of the TIC.  Consequently, larger properties may be purchased while keeping the minimum investment size to around $100,000.  Finally, DSTs do not allow for any input from beneficial interest owners, unlike TICs, which need to get unanimous approval from all TIC members.
    Jokingly, a wise man once told me that a DST is the “Arnold Schwarzenegger version of a TIC.”
    Conclusion
    DSTs and TICs afford individual investors entry into large commercial property, either through a cash investment (typically $100,000 and up) or a 1031 exchange of real assets. Before investing in a DST or TIC, be certain to research the property and the company sponsoring the DST or TIC, and engage a qualified intermediary for your like-kind exchange.

  • Fractional Ownership of Real Estate

    There are many benefits to owning real estate – appreciation, diversification, mortgage interest deduction, and 1031 tax deferment are a few. However, not everyone has the capital to purchase high-end properties like a Donald Trump. Because of the high cost of real estate, many investors seek out angel funding and bank loans to make up their capital shortfalls. Yet, there is another way for an investor to own real estate, and that is fractional ownership. Fractional ownership is an investment structure that allows multiple investors to purchase a percentage ownership in an investment-grade asset.
    Benefits of Fractional Ownership of Real Estate
    Diversification
    Fractional ownership, formerly the province of the savvy mogul who has built a career owning, operating, leasing, and selling real estate, has attracted individual investors who seek an alternative investment to stocks, bonds, and mutual funds they may already own. Fractional real estate ownership and other alternative investments provide for diversification, and financial advisors will often dedicate 10% of a clients’ portfolio towards such vehicles.
    The 3 T’s of Real Estate
    Fractional ownership can be very attractive to real estate investors who wish to unburden themselves of real estate’s 3 T’s (tenants, toilets, and trash). The day-to-day realities of owning real estate – grounds maintenance, property up-keep, and leasing – are not an issue for fractional owners. Investors can enjoy all the benefits of a solid return while not laboring over the 3 T’s.
    Options for Fractional Ownership of Real Estate
    In the United States, there are two primary options for those interested in fractional real estate ownership:  Delaware Statutory Trust (DST) and Tenant-In-Common (TIC) ownership. Each option has become increasingly popular as an alternative investment over the past decade because each affords opportunities for individual investors to own investment-grade property – commercial real estate with more income-generating potential than smaller residential property.
    Tenant-in-Common (TICs)
    Tenant-in-common (TIC) is an investment property structure that was established during the 1990s and has grown in popularity since. Think of a TIC as a form of shared tenure rights to properties owned.  Tenants-in-common each own a separate interest in the same real property. The advantages of a TIC are that each tenant-in-common has stronger buying power and fewer costs, and that each shares responsibilities for a property that is owned by the partnership. 
    Delaware Statutory Trusts (DSTs)
    DSTs are legal entities created as trusts within the state of Delaware in which each investor owns a “beneficial interest” in the DST. DSTs have gained popularity over the last few years due to the ability to secure financing and attract more investors with lower minimum investment thresholds. Another advantage of a DST is that a lender underwrites a single borrower, as opposed to the multiple borrowers within the TIC structure. Furthermore, there is no stated IRS limit to the number of investors a DST may have, versus the 35 maximum of the TIC.  Consequently, larger properties may be purchased while keeping the minimum investment size to around $100,000.  Finally, DSTs do not allow for any input from beneficial interest owners, unlike TICs, which need to get unanimous approval from all TIC members.
    Jokingly, a wise man once told me that a DST is the “Arnold Schwarzenegger version of a TIC.”
    Conclusion
    DSTs and TICs afford individual investors entry into large commercial property, either through a cash investment (typically $100,000 and up) or a 1031 exchange of real assets. Before investing in a DST or TIC, be certain to research the property and the company sponsoring the DST or TIC, and engage a qualified intermediary for your like-kind exchange.

  • New Study Confirms Like-Kind Exchanges Encourage Job Creation and Stimulate Economic Growth

    A new, in-depth study of the U.S. commercial real estate market found that 1031 like-kind exchanges strengthen the market and stimulate job creation, investment, and economic growth.
    “The Economic Impact of Repealing or Limiting Section 1031 Like-Kind Exchanges in Real Estate” analyzed more than 1.6 million real estate transactions over an 18-year period. It was commissioned by the Real Estate Like-Kind Exchange Coalition, comprised of organizations across all sectors of the industry, in response to legislative proposals to repeal Section 1031.

  • New Study Confirms Like-Kind Exchanges Encourage Job Creation and Stimulate Economic Growth

    A new, in-depth study of the U.S. commercial real estate market found that 1031 like-kind exchanges strengthen the market and stimulate job creation, investment, and economic growth.
    “The Economic Impact of Repealing or Limiting Section 1031 Like-Kind Exchanges in Real Estate” analyzed more than 1.6 million real estate transactions over an 18-year period. It was commissioned by the Real Estate Like-Kind Exchange Coalition, comprised of organizations across all sectors of the industry, in response to legislative proposals to repeal Section 1031.