Tax research

You work as a tax professional and one of your best clients, Owen Wilson, has called you to receive some advice. Owen owns and operates his own farming business and his brother, Luke, owns and operates his own cattle company. Owen and Luke have been talking and Luke would like to buy some of Owen’s hay fields for his cattle. Owen wanted to know how much gain that would create and what the tax consequences would be. You vaguely remember something called a like-kind exchange and discuss with Owen the possibility that there would not be any immediate tax consequences if the transaction meets like-kind exchange rules. You discuss potential property that could be exchanged and have the following scenarios: 1. Owen mentions that Luke owns a tractor and a storage building that he doesn’t use much but Owen would be able to use for his farm. Owen is unsure if Luke would be willing to give up this property. 2. Owen knows that Luke does have the cash to pay Owen for the hay fields. You mention the possibility of using an escrow agent (qualified intermediary) to receive the cash from Luke and find qualifying like-kind property for Owen. You tell Owen that you will have to do a little research and get back to him on how to properly handle this transaction to achieve a tax-free result because you know there could be issue due to Owen and Luke being related. You do a little research and come up with the following results:
Use the above authorities and what you know of like-kind exchanges to write Owen a letter indicating your conclusion and advice. Address the following issues: a. Will scenario #1 qualify for like-kind exchange treatment? Why or why not? b. Will scenario #2 qualify for like-kind exchange treatment? Why or why not? c. Conclude by advising Owen on how to structure this transaction to achieve a tax-free result. 1. What items need to be considered because Owen and Luke are related?

You work as a tax professional and one of your best clients, Owen Wilson, has called you to receive some advice. Owen owns and operates his own farming business and his brother, Luke, owns and operates his own cattle company. Owen and Luke have been talking and Luke would like to buy some of Owen’s hay fields for his cattle. Owen wanted to know how much gain that would create and what the tax consequences would be. You vaguely remember something called a like-kind exchange and discuss with Owen the possibility that there would not be any immediate tax consequences if the transaction meets like-kind exchange rules. You discuss potential property that could be exchanged and have the following scenarios: 1. Owen mentions that Luke owns a tractor and a storage building that he doesn’t use much but Owen would be able to use for his farm. Owen is unsure if Luke would be willing to give up this property. 2. Owen knows that Luke does have the cash to pay Owen for the hay fields. You mention the possibility of using an escrow agent (qualified intermediary) to receive the cash from Luke and find qualifying like-kind property for Owen. You tell Owen that you will have to do a little research and get back to him on how to properly handle this transaction to achieve a tax-free result because you know there could be issue due to Owen and Luke being related. You do a little research and come up with the following results:

Use the above authorities and what you know of like-kind exchanges to write Owen a letter indicating your conclusion and advice. Address the following issues: a. Will scenario #1 qualify for like-kind exchange treatment? Why or why not? b. Will scenario #2 qualify for like-kind exchange treatment? Why or why not? c. Conclude by advising Owen on how to structure this transaction to achieve a tax-free result. 1. What items need to be considered because Owen and Luke are related?

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