The short answer
A reverse exchange under a qualified exchange accommodation arrangement is reported on the same Form 8824 as any other exchange, filed for the year you transferred the relinquished property. The Form 8824 instructions say the accommodation titleholder may be treated as the beneficial owner while it holds the property, so the property it transfers to you is what you received and the property you transfer to it is what you gave up. Your dates are those transfers to and from you, not the day the titleholder bought. The titleholder, not you, reports the property's tax attributes while it is parked.
At a glance
| Which year | The year you transferred the relinquished property |
|---|---|
| Beneficial owner while parked | The accommodation titleholder, for all federal income tax purposes |
| Line 6 | Date the titleholder transferred the parked replacement to you |
| Identification | Relinquished property named within 45 days of the titleholder's acquisition |
| Time limit | Transfer within 180 days; combined parking no more than 180 days |
| Agreement | Signed within five business days of the titleholder taking title |
| Prior ownership bar | No safe harbor if you owned the replacement in the prior 180 days |
The titleholder is the owner while it holds the property, and the form follows that
Rev. Proc. 2000-37 is the safe harbor for parking. Its section 4.02(3) requires a written qualified exchange accommodation agreement, signed within five business days of the titleholder receiving title, which must 'specify that the exchange accommodation titleholder will be treated as the beneficial owner of the property for all federal income tax purposes,' with both parties reporting consistently.
The Form 8824 instructions apply that directly: the property transferred from the titleholder to you 'may be treated as property you received in an exchange,' and the property you transferred to it as property you gave up, 'even if the property you are to receive is transferred to the EAT before you transfer the property you are giving up.'
So the parked months belong to the titleholder for tax purposes, including depreciation and rental income on the parked property. You report the exchange when it happens to you.
Your dates are the transfers to and from you, and the 45 days run backwards
Line 4 asks for the date 'you actually transferred your property to the other party' and line 6 the date 'you actually received the like-kind property.' In the common structure, where the titleholder parks the replacement, line 4 is your relinquished closing and line 6 is the day the titleholder transfers the replacement, or the single-member LLC holding it, to you, often the same day.
Line 5 asks for the identification date of the property you received. In a reverse, Rev. Proc. 2000-37 section 4.02(4) instead requires the relinquished property to be identified within 45 days after the titleholder acquires the replacement. The instructions also say that if you received the replacement within 45 days of your transfer, you enter the receipt date on line 5 and are treated as having met the written identification rule.
Keep the relinquished identification notice in the file anyway, because it is what proves the safe harbor's 45-day condition. The structure itself is explained in the reverse 1031 exchange guide.
Worked example: parked June 1, sold October 5
Hypothetical; your own dates and agreement govern. An accommodation titleholder's LLC buys your replacement on June 1, 2026 with money you lend it. You identify your rental as the relinquished property by July 16, day 45, and the titleholder must transfer the replacement to you by November 28, day 180.
Your rental sells on October 5, 2026. Through your intermediary the sale proceeds repay the loan you made to the titleholder, and the titleholder assigns the LLC interest to you the same day.
Your 2026 Form 8824 shows 10/05/2026 on line 4 and on line 6, and, because you received the replacement within 45 days of the transfer, 10/05/2026 on line 5 as well. Part III is computed as in any exchange, with the replacement's value on line 16.
- June 1 to October 5: the titleholder reports the property.
- October 5: you report the exchange on your 2026 return.
- From October 5, the replacement's tax attributes are yours.
One exchange is one form, and a reverse that never finishes is not an exchange
A reverse exchange that pairs one parked replacement with one sale is a single exchange and a single Form 8824. If you have genuinely separate exchanges in the year, the instructions allow a summary Form 8824 with a statement for each; the rules for several properties in one exchange are in Form 8824 with multiple properties or DSTs.
Section 4.02(5) of Rev. Proc. 2000-37 requires the parked property to be transferred within 180 days, and section 4.02(6) caps combined parking at 180 days. If your relinquished property does not sell in time, the parked property falls outside the safe harbor; whatever the titleholder then transfers to you is a purchase to be reported on its own terms, not an exchange.
Rev. Proc. 2004-51 adds a further bar: the safe harbor does not apply to replacement property you owned within the 180 days before the titleholder took title. That is why parking cannot be used to exchange into a property you already own; see building on land you already own.
Where a trust interest replaces the parking structure
If the reason for parking is the fear of having nothing to buy after the sale, naming a Delaware statutory trust interest on a standard 45-day list can serve the same purpose without a titleholder, and a standard exchange reports more simply. The trade-offs are in buying a DST before the property sells and using DSTs as backup properties.
If you do park, give your CPA the accommodation agreement, the titleholder's acquisition and transfer documents, the loan papers between you and the titleholder, and both closing statements; the general list is in documents your CPA needs from the QI.
Related questions
Do I depreciate the replacement while the titleholder holds it?
No. The accommodation agreement treats the titleholder as beneficial owner for all federal income tax purposes during the parking period, so its tax attributes are reported by the titleholder.
Is line 4 the date the titleholder bought the replacement?
No. Line 4 is the date you transferred your relinquished property, and line 6 is the date the titleholder transferred the replacement to you.
Do I file anything in the year the titleholder buys if my sale closes the next year?
Form 8824 goes with the return for the year you transfer the relinquished property, so a June purchase by the titleholder and a February sale are reported on the February year's return.
What if the titleholder parked my relinquished property instead?
Then you transfer the relinquished property to the titleholder and receive the replacement at the start, and both dates reflect that swap; the titleholder later sells the relinquished property to a buyer.
Can improvements built while the property was parked count?
Improvements completed while the titleholder holds the property are part of what is transferred to you, which is how build-to-suit exchanges work; see the improvement exchange guide.
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.