DEFERRED EXCHANGES

Non-Safe Harbor Exchanges

When a transaction falls outside the 180-day “Safe Harbor” window—often due to large-scale construction, rezoning, or complex litigation—a Non-Safe Harbor Exchange is the only viable path. These structures are not “unsafe,” but they do require a higher level of legal sophistication and a “benefits and burdens” test to satisfy the IRS that the taxpayer is not the owner during the parking period.

Drawing on over 30 years of experience, we specialize in these specialty transactions that most standard QIs avoid. We work alongside your legal and tax counsel to build a robust, defensible structure that extends beyond traditional timelines, ensuring your long-term project or complex renovation remains eligible for full tax deferral.