Laws, Regulations & Annotations

C

220.0000 CHANGE IN OWNERSHIP

Annotation 220.0199

220.0199 Exchange—Internal Revenue Code Section 1031. The transfer of real property to a "strawman", i.e., a person who obtains title solely for the purpose of conveying it pursuant to an agreement intended to effect an Internal Revenue Code section 1031 tax-free exchange, does not result in a change of ownership. The transfer by the "strawman" to a third party is a change in ownership unless that third party is an individual or entity who/that owns all interests in the original transferor and the ultimate third party transferee. Since the strawman or strawmen has/have no beneficial interest in the property, neither are owners for change in ownership purposes. C 7/5/1988; C 6/5/1997.