IRS Issues Revenue Procedure on TICs
The IRS and the Department of the Treasury issued Revenue Procedure 2002-22 in March of 2002. Rev. Proc. 2002-22 established guidelines under which the Internal Revenue Service would consider issuing a Private Letter Ruling or PLR for TIC investment property ownership interests acquired as like-kind replacement properties as part of a real estate investor's tax-deferred exchange transaction pursuant to Section 1031 of the Internal Revenue Code.
Rev. Proc. Provides Guidelines; Not Safe Harbor Provisions
It is important to note that Rev. Proc. 2002-22 contained guidelines for TIC Sponsors to follow and did not provide any "safe harbor" or "guaranteed" structures for TIC investment properties.
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