Identification and Purchase Deadlines that fall between April 1, 2020 and July 15, 2020 will be Extended to July 15, 2020.
The IRS Notice 2020-23 (which updates Notice 2020-18, “Additional Relief for Taxpayers Affected by Ongoing Coronavirus Disease 2019 Pandemic”), released on April 9, 2020, provides Taxpayers currently engaged in a 1031 exchange some relief from the 45-Day Identification and 180-Day Exchange Period deadlines.
The notice provides that any person performing a time-sensitive action listed in either § 301.7508A-1(c)(1)(iv) – (vi) of the Procedure and Administration Regulations or Revenue Procedure 2018-58, 2018-50 IRB 990 (December 10, 2018), which is due to be performed on or after April 1, 2020, and before July 15, 2020 (Specified Time-Sensitive Action), is an Affected Taxpayer.
Section C of the Notice states that “Affected Taxpayers also have until July 15, 2020, to perform all Specified TimeSensitive Actions, that are due to be performed on or after April 1, 2020, and before July 15, 2020.” This appears to provide that any Affected Taxpayer with a 45-Day Exchange Period or 180-Day Exchange Period deadline between April 1 and July 15, 2020 will receive an automatic extension to July 15, 2020.
