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Answers · Exchange paperwork

What documents does my CPA need from the QI to report the exchange?

Your CPA needs the exchange agreement, both closing statements, the 45-day notice, the QI's final accounting, the 1099-S and the loan payoff, each feeding Form 8824.

By Breakwater Exchange · Reviewed by our 1031 advisory team · Last reviewed

The short answer

Six items do almost all the work: the exchange agreement with its assignment notices, the settlement statement for the property you sold, your signed identification notice, the settlement statement for each replacement, the intermediary's final accounting of every dollar in and out, and the Form 1099-S. Add the payoff statement for any loan cleared at the sale and the closing documents for any new loan, because debt moves the numbers on Form 8824 line 15 and line 18. Your CPA already holds the depreciation history that sets your adjusted basis.

At a glance

Exchange agreementShows the intermediary acquired and transferred the property under a written agreement
Sale settlement statementLine 4 date, price, payoff and selling expenses
Identification noticeLine 5 date and the properties named
Purchase settlement statementLine 6 date, line 16 value, new debt and cash you added
QI final accountingFunds received, disbursed and returned, with dates
Form 1099-SGross proceeds the IRS already has
Not exchange expensesTax and rent prorations, security deposits and repairs

Each document answers a specific line, so the list follows the form

Form 8824 asks for dates in Part I and dollars in Part III. Line 4 is the date you transferred your property, line 5 the written identification date, line 6 the date you received the replacement. Lines 15 to 18 need cash or other property received, debt relieved and assumed, the replacement's value, your adjusted basis and exchange expenses.

None of those figures appears on a single page. The sale statement has the price and payoff, the purchase statement has the new loan, and only the intermediary's ledger shows what happened to the money between them.

Get the documents as final, signed versions. Estimated closing statements can differ from the final settlement figures.

From the intermediary: the agreement, the notices and the money trail

The exchange agreement is the core of the safe harbor. Reg. section 1.1031(k)-1(g)(4)(iii) defines a qualified intermediary as a person who 'enters into a written agreement with the taxpayer' and acquires and transfers both properties under it. Paragraph (g)(4)(v) treats the intermediary as a party to your purchase and sale contracts when your rights are assigned and all parties are notified in writing, so ask for the signed assignment notices as well.

The identification notice proves the 45-day rule. Paragraph (c)(2) requires a written document signed by you and delivered before the end of the identification period; your CPA needs the copy with its delivery date for line 5.

The final accounting closes the loop: deposits from the sale, wires to each replacement closing, fees, any interest earned and any amount released to you with its date. Released cash is boot, and its date can decide the year it is reported, as leftover cash after a 1031 exchange explains.

From the closings: two settlement statements, the 1099-S and the loan papers

Publication 544 says exchange expenses generally include closing costs on the sale, such as brokerage commissions, attorney fees and deed preparation fees, and closing costs on the purchase. It also says items such as property taxes, rent prorations, security deposits and repairs are not exchange expenses, so your CPA needs the itemized statements to separate them. The detail is in the settlement statement for a 1031 exchange.

The Form 1099-S is filed by the settlement agent and generally shows the contract price. Your CPA uses it to make sure the return explains that figure; see my 1099-S shows the full sale price.

Debt needs its own papers. The Form 8824 instructions count net liabilities assumed by the buyer on line 15 and net amounts you paid on line 18, so the payoff statement for the old loan and the closing disclosure for the new one are both required.

Worked example: one sale, one purchase, eight documents

Hypothetical; your list grows with each additional property. You sell a rental with a mortgage and buy one replacement with a new loan, adding a little of your own cash. Your CPA's file should hold the documents below, each tied to the lines it supports.

If one replacement was a Delaware statutory trust interest, add the subscription agreement and the sponsor's purchase confirmation, which show the date your interest was acquired and the amount. The allocation across several replacements is in Form 8824 with multiple properties or DSTs.

Keep a copy of the whole file with the return. The records question for later years is covered in what records to keep for a 1031 audit.

  • Exchange agreement and assignment notices: proof of the intermediary arrangement.
  • Sale settlement statement: line 4, price, payoff, selling expenses.
  • Old loan payoff statement: debt relieved for line 15.
  • Identification notice with delivery proof: line 5.
  • Purchase settlement statement: line 6, line 16, purchase expenses.
  • New loan closing disclosure and any cash you wired: line 18.
  • Intermediary's final accounting and any interest statement: boot, fees and income.
  • Form 1099-S: the figure the return must explain.

Ask for these before day 180, not at tax time

Request the intermediary's final accounting as soon as the last replacement closes, rather than waiting for filing season. Interest on exchange funds is taxable to someone: under Reg. section 1.468B-6(c), if the agreement pays all earnings to you, you take them into account; otherwise the funds are treated as loaned to the intermediary. See interest on exchange funds.

If your sale closed late in the year, the return may need to wait for the purchase; see which year to file Form 8824.

Related questions

Does the intermediary prepare Form 8824 for me?

Plan on your CPA preparing it. The intermediary's role is to hold the funds and handle the transfers; the return is yours. See does the exchange company give tax advice.

Is the closing statement enough without the intermediary's ledger?

No. The closing statements show what moved at each closing, but only the ledger shows amounts held, fees charged, interest earned and money returned to you.

Which document proves the 45-day identification?

Your signed identification notice, with evidence of when it was delivered to the intermediary or another permitted party.

Will I get a 1099 for interest the intermediary earned?

If the earnings are yours under the agreement, they are reported to you to the extent the information reporting rules require. Ask the intermediary which form it issues.

Does a reverse exchange need extra documents?

Yes. Add the qualified exchange accommodation agreement and the documents showing when the accommodation titleholder acquired and transferred the property; see Form 8824 for a reverse exchange.

Sources

Checked against these publications on September 30, 2026. Rules and figures change; confirm the current version with your CPA or attorney before you act. This page is general information, not tax or legal advice.

  1. IRS, Form 8824 (2025)
  2. IRS, Instructions for Form 8824 (2025)
  3. Treas. Reg. section 1.1031(k)-1, identification and qualified intermediaries
  4. Treas. Reg. section 1.468B-6, exchange funds
  5. IRS, Publication 544 (2025)

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