Other People's Money
Back to library
Loophole

§121 + §1031 Combo (Rev Proc 2005-14)

Convert rental to primary — stack the $500K exclusion AND remaining 1031 deferral.

Overview

Rev Proc 2005-14 blesses stacking §121 (primary-residence exclusion) with §1031 (like-kind deferral) on a former rental converted to primary. Live in a 1031-acquired rental as primary for 2+ years (after 5 total years of ownership), then sell — exclude $500K under §121 AND continue deferring the original 1031 gain via a new 1031 on the residual. Net: near-total tax elimination on multi-decade appreciation.

Best fit
Long-term real estate investors1031 exchangers approaching retirementSnowbird / dual-residency owners
Estimated impact
Exclude $500K + defer $500K–$5M of remaining 1031 gain

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.

More loophole strategies

See all Loophole strategies
OPM