1031 exchange seller carry back note financing section 453: Disadvantages of the Structured Sale Strategy - 07/26/11 01:58 PM
I posted an article last week regarding the Structured Sale tax deferral strategy.  I received a number of private emails requesting more information, including more information about the potential downside and/or disadvantages of implementing a Structured Sale strategy.  These are great questions, of course, and an important part of your due diligence process. 
Disadvantages of the Structured Sale Strategy
The first (and major) disadvantage is that the Internal Revenue Service has not issued any guidance or rulings related to the Structured Sale at this point in time. 
The second is that Structured Sales are drafted pursuant to Section 453 of the Internal … (5 comments)

1031 exchange seller carry back note financing section 453: Seller Carry Back Notes and 1031 Exchanges - 11/27/07 04:36 AM
There have not been very many seller carry back notes over the last few years, but we are beginning to see more seller carry back financing strategies as interest rates have been adjusting over the last few months and the mortgage and credit markets are correcting.  We expect that this trend in seller carry back notes will continue to grow over the next couple of years.Seller carry back notes can be very powerful transactional strategies when structuring real estate transactions in challenging real estate markets like we are experiencing today. However, seller carry back financing structures can significantly complicate a 1031 … (4 comments)