Open1031 — EAT / Parking Arrangement Hub

EAT / Parking Hub · Reverse Exchange

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EAT / Parking Hub

Exchange Accommodation Titleholder · QEAA + EAT SPE + Parked Replacement · Rev. Proc. 2000-37

2 / 3 steps

QEAA Agreement

EAT SPE Formation

Replacement Parked

Parked Replacement Properties

Each replacement property is held by the EAT. A 45-day identification window and 180-day close deadline run independently from each property's EAT acquisition date. Multiple properties may be parked simultaneously; assign each to a relinquished sale once a match is known.

Parking Summary 2 parked · 1 unassigned

Titleholder Open1031 EAT LLC

Parking status Parked with EAT

Exchange deadline rule 180 days from each EAT acquisition

Relinquished mapping 1 of 2 unassigned — assign after sale closes

2847 Lakeview Drive

Austin, TX 78703

Parked

Purchase price $1,250,000

EAT acquisition May 14, 2026

ID deadline: 14d Close deadline: 41d

Assignment to relinquished sale

456 Sunset Blvd, Los Angeles CA

910 Marina Blvd, Unit 4

San Francisco, CA 94123

Parked

Purchase price $850,000

EAT acquisition Jun 2, 2026

ID deadline: 33d Close deadline: 160d

Assignment to relinquished sale

Not yet assigned to a relinquished sale

This is intentional — assign once the relinquished property sale closes.

1 property has not been assigned to a relinquished sale. Assignments can be made once relinquished sales are added — this is expected for one-to-many parking arrangements.

QEAA Safe-Harbor Attestations · Rev. Proc. 2004-51

§4.02(1) — 180-day prior-ownership look-back clear. The taxpayer has not owned or held an interest in the parked replacement property within the 180-day period ending on the EAT acquisition date (Aug 20, 2026), satisfying the Rev. Proc. 2004-51 §4.02(1) and combined-holding limit of §4.02(6).

§4.02(2) — Bona-fide intent to complete a §1031 exchange. At the time the EAT acquired the replacement property, it was the taxpayer's genuine intent to complete a like-kind exchange under IRC §1031 using that property.

§4.02(3) — Consistent tax reporting. The exchange will be reported on the federal income tax return in a manner consistent with QEAA safe-harbor treatment; the replacement property will not be claimed as owned during the parking period.

Combined 180-day holding limit · §4.02(6). The aggregate period the replacement property is parked with the EAT — across all legs — cannot exceed 180 calendar days. The 45-day identification window and 180-day close deadline each run from the EAT acquisition date, not from closing of the relinquished sale.

Parking Agreement

Parked Replacement Property Identification

Formal identification of replacement properties parked with the EAT · Signed Jun 3, 2026

Signed

I confirm the replacement properties are parked with the EAT and I am ready to proceed with identifying and relinquishing my current property within the 45/180-day windows.