Open1031 — Exchange Sub-Variant Reference

Forward · 1 variant

forward_delayed

Forward (Delayed)

Relinquished property sold first; replacement identified within 45 days, closed within 180 days of relinquished sale close.

Deadline anchor Relinquished sale close

45-day window From sale close date

180-day window From sale close date

Extra hubs None

Sales → ID → Escrow → Purchase → Disburse → IRS

Treas. Reg. §1.1031(k)-1 · the most common exchange type (80%+ of cases)

Simultaneous · 1 variant

simultaneous

Simultaneous

Relinquished and replacement properties close on the same day. No 45-day identification window applies; no deferred period.

Deadline anchor Relinquished sale close

45-day window N/A — same-day close

180-day window N/A — same-day close

Extra hubs None (ID hub dropped)

Sales → Escrow → Purchase → Disburse → IRS

§1031 — concurrent close; no ID or exchange periods apply

Reverse · 2 variants

reverse_exchange_last

Reverse Exchange (Exchange-Last)

Replacement property parked with an EAT before the relinquished property is sold. The "exchange" (relinquish) happens last — the parking arrangement model.

Deadline anchor EAT acquisition date

45-day window From EAT acquisition

180-day window From EAT acquisition

Extra hubs EAT / Parking Hub

EAT → ID → Sales → Escrow → Disburse → IRS

Rev. Proc. 2000-37 · QEAA must be executed within 5 business days of EAT acquisition

reverse_exchange_first

Reverse Exchange (Exchange-First)

Relinquished property parked with an EAT after the replacement is acquired. The "exchange" (relinquish) happens first — then the replacement is released from the EAT.

Deadline anchor EAT acquisition date

45-day window Not applicable (exchange-first)

180-day window From EAT acquisition

Extra hubs EAT / Parking Hub

EAT → Sales → Escrow → Purchase → Disburse → IRS

Rev. Proc. 2000-37 · §4.02 exchange-first safe harbor · less common

Improvement · 3 variants

improvement

Improvement (Build-to-Suit)

Replacement property improved or constructed using exchange funds held by a QEAT. Improvements must be substantially complete by the 180-day deadline.

Deadline anchor Relinquished sale close

45-day window From sale close (identify replacement + improvements)

180-day window Improvements must be substantially complete

Extra hubs Construction Hub

Sales → ID → Escrow → Construction → Disburse → IRS

Treas. Reg. §1.1031(k)-1(e) — build-to-suit; improvements count toward like-kind exchange value

reverse_improvement

Reverse Improvement

Replacement property acquired and improved in a reverse-exchange structure. Both the EAT parking mechanics and the improvement/construction hub apply simultaneously.

Deadline anchor EAT acquisition date

45-day window From EAT acquisition

180-day window Improvements + relinquishment both due

Extra hubs EAT + Construction (both)

EAT → Construction → ID → Sales → Escrow → Disburse → IRS

Most complex variant — requires both Rev. Proc. 2000-37 (QEAA) and improvement-exchange rules

leasehold_improvement

Leasehold Improvement

Leasehold interest in replacement property improved using exchange funds. The lease term must exceed 30 years (including renewal options) to qualify as like-kind property.

Deadline anchor Relinquished sale close

45-day window From sale close

180-day window Improvements substantially complete

Special requirement Lease ≥ 30 years (incl. renewals)

Extra hubs Construction Hub

Sales → ID → Escrow → Construction → Disburse → IRS

Reg. §1.1031(a)-1(c)(2) — leasehold of 30+ years is like-kind to fee interest in real property