TCP Property Transactions, Gain Recognition, and Related-Party Limits

This part covers the property side of TCP. The chapters focus on the rules that decide whether gain or loss is recognized now, deferred, recharacterized, or limited by the relationship between the parties or the structure of the transaction.

In This Part

• Nonrecognition, Like-Kind Exchange, and Involuntary Conversion Rules covers the main deferral and replacement-property frameworks.
• Gain and Loss Character, Recapture, and Installment Reporting explains how character and timing change the tax effect even when the amount of gain is clear.
• Related-Party, Worthless Security, and Disposition Complications addresses the override rules that prevent an otherwise simple property answer.

How to Use This Part

• Read these chapters in order because recognition, basis, and character work together.
• Focus on what changes basis, timing, and character, not just whether a gain exists.
• Return here when missed questions involve exchanges, related parties, or confusing capital-versus-ordinary treatment.

In this section

• Nonrecognition, Like-Kind Exchange, and Involuntary Conversion Rules
  Property-disposition rules covering Section 1031 exchanges, Section 1033 involuntary conversions, and basis effects from boot.
  • Section 1031 Like-Kind Exchange Timelines, Real Estate Scope, and Intermediaries
    Section 1031 exchange rules covering qualifying real estate, deadlines, and qualified intermediary requirements.
  • Section 1033 Involuntary Conversions, Replacement Periods, and Condemnation Awards
    Section 1033 involuntary-conversion rules covering condemnation, disaster events, and replacement-property deadlines.
  • Boot Recognition and Basis Adjustments in Partial Like-Kind Exchanges
    Boot recognition and replacement-property basis adjustments in partial like-kind exchanges.
• Gain and Loss Character, Recapture, and Installment Reporting
  Property-character rules covering Section 1231, depreciation recapture, installment sales, and Section 1202 QSBS exclusions.
  • Section 1231 Netting, Capital Versus Ordinary Character, and the Lookback Rule
    Section 1231 netting rules covering business-property gains, losses, and five-year lookback recharacterization.
  • Depreciation Recapture Under Sections 1245 and 1250
    Depreciation-recapture rules for Sections 1245 and 1250, including ordinary-income conversion and real-property treatment.
  • Installment Sales, Imputed Interest, and Dealer-Disposition Limits
    Installment-sale rules covering gross-profit ratio, imputed interest, and dealer-disposition limits.
  • Section 1202 QSBS Exclusions, Holding Periods, and Eligibility Limits
    Section 1202 QSBS rules covering holding periods, eligibility thresholds, exclusion limits, and state conformity issues.
• Related-Party, Worthless Security, and Disposition Complications
  Property-disposition complications covering related-party loss limits, wash sales, abandonments, and multistate sourcing issues.
  • Related-Party Loss Disallowance, Constructive Ownership, and Deferred Gain Rules
    Related-party property rules covering loss disallowance, ownership attribution, and deferred gain consequences.
  • Wash Sales, Substantially Identical Securities, and Worthlessness Treatment
    Wash-sale timing rules and worthless-security treatment for stock and debt instruments.
  • Abandonments, Partial Dispositions, and Basis Allocation for Real Property
    Real-property disposition rules covering abandonments, partial retirements, and basis allocation.
  • Multi-Jurisdictional Property Dispositions and State Tax Sourcing Issues
    State and local sourcing issues for property transactions spanning multiple jurisdictions.