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Topic 65: Tax Consequences of Like-Kind Exchanges - 207 (3) Depreciable tangible personal property must be in the same asset or product class For example, the exchange does not qualify for Section 1031 if a half-ton truck is traded for a two-ton truck 3 Multiple properties A The exchange is considered one of multiple properties if the transferred properties are separable into more than one exchange group An exchange group consists of all properties transferred and received within an exchange that are of the same asset class or product class B Example: An exchange of a boat for a boat and trailer creates two exchange groups Each exchange group must transfer and receive at least one property C Typical three-cornered exchange involves three parties and quali es for Section 1031 treatment: (1) Buyer Wants to purchase property (2) Trader Wants to sell property, but only for other like-kind property, to avoid taxes (3) Seller Wants to sell property, but owns no new property (4) Buyer wants Trader s property, and Trader wants Seller s property Seller wants to sell (a) The property given up is not converted into cash (b) Intent of trade is established wording must be included in the escrow instructions for Section 1031 exchange D The purchase, sale, and exchange are usually simultaneous, but this is not required When property is sold at different times, the exchange period begins on the date of the rst exchange In a delayed exchange, the replacement property must be designated within 45 days of closing escrow on the relinquished property and close within 180 days E Exchange of one business for another generally does not qualify for Section 1031 treatment, because the assets of one business cannot be grouped together and treated as one asset 4 Liabilities When a taxpayer gives up property that is subject to a liability, and the transferee assumes the liability, then the taxpayer is treated as having received cash in the transaction equal to the amount of the liability being transferred If the taxpayer has liability that is assumed, and in turn assumes a liability on the replacement property, the liabilities are netted together to calculate the cash received or paid 5 Boot A Characteristics (1) All property other than like-kind (nonqualifying property) (2) Cash B Exchange of mortgage properties (1) Relief of debt is boot received whether loan or mortgage (treated as cash received) (2) Assumption of debt is boot given (treated as cash paid) Example: ABC and XYZ exchange property A and property B as follows: Property A XYZ Property B ABC FMV = $670,000, debt = $175,000, basis = $200,000 FMV = $495,000, debt = $0, basis = $415,000).

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void CTestClass::TestValue(TInt aValue) { __ASSERT_DEBUG((aValue> =0), Panic(EInvalidTestValueInput)); }

Section 409 Section 409 requires near-real-time reporting of all material events, whether internal or external, to investors and the appropriate regulatory bodies This can be accomplished by using a single, enterprisewide document management system that can issue appropriate alerts, and that has the notifications and workflow functions configured according to the design of the compliance-based business processes Such a system ensures that all relevant information is relayed almost immediately to top management (CEO and CFO), the compliance committee, and the advisors, with minimum delay or latency The capabilities of DMS allow the compliance advisors to make a recommendation (within the stipulated time frame) linked to each alert and send on the reports to the executives with the appro-

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ABC Amount realized: Value of realty acquired Boot received (debt relief) Basis of property surrendered: Realty Boot paid (debt assumed) Gain realized Gain recognized* Gain deferred

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The advantage of using an identi able panic descriptor and enumerated values for different assertion conditions is traceability, both for yourself and clients of your code, when an assertion fails and a panic occurs This is particularly useful for others using your libraries, since they may not have access to your code in its entirety, but merely to the header les If your panic string is clear and unique, they should be able to locate the appropriate class and use the panic category enumeration to nd the associated failure, which you will have named and documented clearly to explain why the assertion failed There may be cases where there s nothing more a client programmer can do other than report the bug to you, the author of the code; alternatively, the problem could be down to their misuse of your library, which they ll be able to correct I ll discuss the pros and cons of using assertions to protect your code against badly-programmed calling code later in this chapter If you don t want or need an extensive set of enumerated panic values, and you don t expect external callers to need to trace a panic, you may consider using a more lightweight and anonymous assertion A good example of this is to test the internal state of an object, which could not possibly be modi ed by an external caller, and thus should always be valid unless you have a bug in your code Assertions can be added early in the development process, but left in the code, in debug builds, to validate the code as it is maintained and refactored In these cases, you may consider using the ASSERT macro, de ned in e32defh as follows:

XYZ $670,000 0 $670,000 (415,000) (175,000) $80,000 $0 80,000 $80,000

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#define ASSERT(x) __ASSERT_DEBUG(x, User::Invariant())

$495,000 175,000 $670,000 ($200,000) 0 $470,000 $175,000 295,000 $470,000

C Basis of assets received (1) Reduced by (a) Cash (boot) received (b) Loss recognized (c) Liabilities conveyed (2) Increased by (a) Cash (boot) paid (b) Gain recognized (c) Liabilities assumed

I like this macro because it doesn t need you to provide a panic category or descriptor If condition x is false, in debug builds only, it calls User::Invariant() which itself panics with category USER and reason 0 The macro can be used as follows:

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