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Improvement (Build-to-Suit) 1031 Exchange

EAT parks replacement land; construction improvements added within 180 days count toward exchange value — no boot.

Overview

When replacement property costs less than relinquished proceeds, boot (taxable gain) results. Solution: Improvement Exchange — a Qualified Intermediary (via Exchange Accommodation Titleholder, EAT) parks title to a replacement parcel and directs construction improvements during the 180-day window. The value of both land + completed improvements counts toward the replacement value, eliminating boot. Complex: requires EAT structure, construction financing to the EAT (not you), certificate of occupancy before day 180. Great for exchanging into a purpose-built property.

Best fit
1031 exchangers with excess proceedsInvestors building custom facilitiesReal estate developers
Estimated impact
Eliminate 20–28% cap gain + recapture on boot

Click Generate advisory deep dive for mechanics, IRC citations, a step-by-step execution plan, a worked numeric example on your profile, costs, risks, and this-week actions.

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