“Repetitive” Personal Property Exchanges

Working with another exchange intermediary client, Montgomery McCracken tax attorneys helped to pioneer a tax planning technique for automobile leasing companies involving “repetitive” like-kind exchanges of vehicles. In these exchange programs, each sale of a vehicle coming off lease commences an exchange for a “matched” new vehicle acquired from a manufacturer or dealer. Montgomery McCracken attorneys assisted in obtaining private letter rulings from the IRS for these initial transactions and worked with Bar Association and industry groups in ultimately obtaining published “safe harbor” guidance from the IRS approving these programs. Montgomery McCracken has also helped establish similar programs for companies that lease construction equipment.