Safe Harbor Rules: After the exchanger has given up the propety, the exchangor is is unwilling to accept the buyer's unsecured promise to transfer the replacement property. The exchangor normally structures the exchange where the buyer's obligaion is guarnanteed using an escrow arrangement, but the exchangor must avoid actual or constructive receipt of the property.
Substantial limitations or restrictions exist if the taxpayer doesn't have the right to receive the benefits of the property, or money until>
. 46 days after identification period and befoe the 181 day of the transfer of title of property being exchanged.
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