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Exchange Accommodation Titleholder (EAT)

An Exchange Accommodation Titleholder (EAT) is a legal entity that temporarily holds title to both the relinquished property being sold by the taxpayer and the replacement property being purchased by the taxpayer in a like-kind exchange. The EAT serves as a “middleman” in the transaction, allowing the taxpayer to sell their relinquished property and acquire their replacement property without triggering a tax liability on the transaction.

The EAT structure is commonly used in situations where there is a timing gap between the sale of the relinquished property and the purchase of the replacement property, or where there are other complexities that make it difficult for the taxpayer to directly exchange properties with another party. The EAT holds the title to the replacement property during the interim period and then transfers it to the taxpayer once the sale of the relinquished property is complete.

The use of an EAT in a 1031 exchange requires careful planning and adherence to specific IRS guidelines to ensure that the transaction is considered a valid exchange and not a taxable sale.