Advanced 1031 Exchanges: Mastering Partnership Challenges, Reverse, and Construction Exchanges

Miranda Byrd | First American Exchange Company

Miranda Byrd is the Business Development Manager for Kentucky and Tennessee for First American Exchange Company, a division of First American Financial Corporation. She is experienced in facilitating traditional forward 1031 exchanges, as well as reverse and improvement exchanges. She is a regular speaker on the topic of 1031 exchanges and consults multiple people daily on this topic.

Professional problem solver for over 20 years with significant experience representing banks, investors and creditors in transactions and litigation. Relationship builder who fosters trust and rapport with clients by understanding their needs. Proven ability to handle high-pressure situations, maintaining composure and making sound decisions under tight deadlines and challenging circumstances.

Prior to joining First American Exchange Company, Miranda practiced law for 20 years in Chicago, Illinois. She has extensive experience in real estate and banking transactions and litigation and is licensed in Illinois and Tennessee.

I. Navigating Partnership Challenges in 1031 Exchanges | 1:00pm – 1:30pm

• Partnership structures and their impact on 1031 exchanges
• Drop and swap vs. swap and drop strategies: Key considerations
• Handling disagreements among partners regarding exchange vs. cash-out options
• Structuring exchanges involving LLCs, Tenants-In-Common (TIC), arrangements, and Delaware Statutory Trusts (DSTs)
• IRS scrutiny and compliance risks in partnership-driven exchanges
• Avoiding common pitfalls in partnership 1031 exchanges

II. Reverse Exchanges: Strategies and compliance | 1:30pm – 2:00pm

• Understanding reverse exchanges: When and why they are used
• The role of an exchange accommodation titleholder (EAT)
• Parking arrangements and the 180-day rule
• Financing challenges and structuring solutions in reverse exchanges
• Tax and reporting considerations for reverse exchanges

Break | 2:00pm – 2:10pm

III. Construction (Improvement) Exchanges: Maximizing value | 2:10pm – 2:40pm

• Key rules and requirements for construction exchanges under 1031
• Structuring build-to-suit exchanges within the 180-day timeframe
• Financing challenges and lender considerations
• Dealing with partially completed improvements and valuation concerns
• IRS safe harbors and potential risks in construction exchanges