The QI File

Reverse / parking · not tax or legal advice

Choosing a QI for a reverse exchange

A reverse (parking) exchange is used when the replacement property must be acquired before the relinquished property is sold. The written safe harbor is Rev. Proc. 2000-37: an exchange accommodation titleholder holds the parked asset under a qualified exchange accommodation arrangement. Rev. Proc. 2004-51 limits that safe harbor when the taxpayer already owned the intended replacement property in the prior 180 days. Choosing a QI for that stack is an operations and custody decision — who is the EAT, who signs, who funds construction if any, and whether the firm has actually papered a parking file. This page defines the structure, lists questions, and links every firm in The QI File that publishes reverse or parking language. Publication is not a ranking and not a capability audit.

Definition (from the revenue procedures)

Rev. Proc. 2000-37 (2000-2 C.B. 308) treats the EAT as the beneficial owner of the parked property for federal income-tax purposes if the listed QEAA conditions are met. Either the replacement or the relinquished property can be parked. The procedure is a safe harbor, not the only theoretically possible structure.

Rev. Proc. 2004-51: the 2000-37 safe harbor does not apply if the taxpayer owned the intended replacement property during the 180-day period ending on the transfer of qualified indicia of ownership to the EAT. Read the PDF; do not treat “we parked it” as a 2000-37 file if the taxpayer already owned the target.

Longer type definitions, including improvement/build-to-suit combinations, live onforward vs reverse vs improvement.

What to ask before the EAT is stood up

  • Who is the EAT — a sole-purpose LLC, an affiliate, or the QI’s operating company — and who owns it?
  • Will the documents be a QEAA intended to fit 2000-37, and have you run the 2004-51 ownership test on these facts?
  • Who signs parking title, insurance, and the lender package? Will the lender sit on EAT title?
  • What is the published or quoted fee for this reverse (see QI fees — most firms have no public reverse number)?
  • If improvements will be built while parked: draw control, lien waivers, and what is “received” by day 180.
  • Account title and who can wire parked proceeds or construction funds — still a custody question, same as a delayed file.

Directory firms that publish reverse or parking

Alphabetical. “Publishes reverse” means reverse: yes on the custody file — sourced from that firm’s cited pages. It is not an audit, not a recommendation, and not ordered by size, fee, or parent. Firms that do not publish reverse stay off this list even if they would take a parking file if asked.

76 listings as of this build. The live directory table is on thehomepage.

FAQ

What is a reverse 1031 exchange?

Practitioners use “reverse” when replacement property must be acquired before the relinquished property is sold. Rev. Proc. 2000-37 provides a safe harbor in which an exchange accommodation titleholder (EAT) holds parked property under a qualified exchange accommodation arrangement (QEAA). It is a safe harbor, not a separate Code section named reverse exchange, and not a guarantee that a given parking deal fits.

What did Rev. Proc. 2004-51 change?

Rev. Proc. 2004-51 states that the 2000-37 safe harbor does not apply if the taxpayer owned the property intended to qualify as replacement property during the 180-day period ending on the date qualified indicia of ownership of that property are transferred to the EAT. Ask counsel before treating a “we already bought it” fact pattern as a 2000-37 file.

Does a “Reverse published” listing mean the firm can do my parking exchange?

No. The directory flag means the firm’s cited public pages mention reverse, parking, or EAT work. That is a publication fact, not an audit of documents, lenders, or recent closings. There is no ranking on this page.

Is a reverse exchange a securities offering?

No. Parking title with an EAT is QI / accommodation-titleholder custody. A Delaware Statutory Trust interest used as replacement property is typically a securities offering. Do not conflate the two. See QI custody vs DST offerings.

Related

Sources

  • Rev. Proc. 2000-37 — irs.gov/pub/irs-drop/rp-00-37.pdf. QEAA / EAT parking safe harbor. Accessed 2026-09-08.
  • Rev. Proc. 2004-51 — irs.gov/pub/irs-drop/rp-04-51.pdf. Safe harbor unavailable if the taxpayer owned the intended replacement property in the 180 days before transfer to the EAT. Accessed 2026-09-08.
  • Treas. Reg. §1.1031(k)-1 — 26 C.F.R. §1.1031(k)-1. Delayed-exchange safe harbors; not a reverse-exchange statute. Accessed 2026-09-08.

Firm inclusion is a publication flag from how to read a listing, not an IRS classification. This is QI / EAT custody language, not a DST securities offering.