The short answer
Yes, when the replacement is the parked property. Rev. Proc. 2000-37 requires that 'no later than 45 days after the transfer of qualified indicia of ownership of the replacement property' to the titleholder, 'the relinquished property is properly identified,' using the identification rules of the deferred exchange regulations. You may name alternatives, so an owner of several rentals can list up to three and sell whichever finds a buyer first. In the exchange-first structure, where the titleholder holds your old property, the property you are giving up is fixed by the exchange documents on day one.
At a glance
| Deadline | 45 days after the titleholder takes title to the replacement |
|---|---|
| Rule source | Rev. Proc. 2000-37 section 4.02(4) |
| Manner | Signed written notice, as in Reg. section 1.1031(k)-1(c) |
| Alternatives allowed | Yes, under the multiple-property rules |
| Three-property rule | Up to three properties regardless of value |
| Sale deadline | An identified property must sell within 180 days |
| Exchange-first form | Relinquished property deeded to the titleholder at the start |
The forward-exchange rule runs backwards: you name what you will sell
In a normal exchange you sell first and identify replacements. In an exchange-last reverse, the replacement is already chosen and sitting with the titleholder, so the uncertainty is on the other side. Section 4.02(4) of Rev. Proc. 2000-37 therefore requires identification of the relinquished property within 45 days of the titleholder's acquisition.
Identification 'must be made in a manner consistent with the principles described in' Reg. section 1.1031(k)-1(c), and the procedure adds that 'the taxpayer may properly identify alternative and multiple properties.'
Both clocks start with the titleholder's acquisition, not with any sale, as explained in when the 45-day clock starts.
The notice follows the same form as any identification
Under Reg. section 1.1031(k)-1(c)(2), the designation must be in 'a written document signed by the taxpayer' and sent before the deadline to a person involved in the exchange who is not you or a disqualified person, such as the intermediary or escrow agent.
The titleholder can usually receive it, because section 3.03 of the revenue procedure says acting as titleholder does not by itself make a person disqualified. Describe each property unambiguously: a legal description, street address or distinguishable name, per paragraph (c)(3).
Changes follow paragraph (c)(6): a revocation must also be in a signed writing sent before the 45-day period ends to the person who received the original notice. After that date the list is fixed.
Keep a copy with proof of delivery date. The same discipline used for replacement lists applies, see how to identify replacement property.
Three properties or the 200 percent test decide how many you can name
Paragraph (c)(4) allows three properties 'without regard to the fair market values' or any number whose aggregate value does not exceed 200 percent of the benchmark. Those tests were written for replacement lists, and Rev. Proc. 2000-37 imports them by reference without saying how the 200 percent comparison is measured when the list is of relinquished property.
The three-property rule is unambiguous, so most owners stay within it. Over-identifying risks being treated as having identified nothing, because paragraph (c)(4)(ii) says that a taxpayer who names more properties than permitted 'is treated as if no replacement property had been identified.'
Choose the three with care. List the properties most likely to close inside 180 days at a price that covers the replacement and its debt, not the ones you most want to sell. A property with title problems, a tenant dispute or a pending appraisal gap is a poor candidate however eager you are to be rid of it.
The forward-exchange version of these counting rules is explained in how many properties you can identify.
Worked example: three rentals, one parked duplex, the first sale wins
Hypothetical, round numbers; run your own numbers with your CPA. The titleholder buys a $750,000 duplex on April 1. You own three rentals worth about $500,000, $600,000 and $700,000, all listed for sale.
By May 16, day 45, you deliver a signed notice naming all three. On day 140 the $600,000 rental sells, the intermediary uses the proceeds to acquire the duplex from the titleholder, and the exchange is complete. The other two rentals remain yours and can be sold later in separate exchanges.
Had you named only the $700,000 rental and it failed to close, the sale of the $600,000 one would not have completed this exchange. That outcome is described in what happens if the property does not sell within 180 days.
In the exchange-first form, the question answers itself
Rev. Proc. 2000-37 section 2.05 describes the other pattern: the titleholder buys the replacement and 'immediately exchange[s] such property with the taxpayer for the relinquished property', then holds the old property until a buyer is found.
Your relinquished property is the one you deeded to the titleholder on that day, so there is no list to prepare. The work moves to selling it within 180 days, because section 4.02(5) requires the titleholder to transfer it to an unrelated buyer by then.
Which structure suits you depends mostly on financing, covered in who funds a reverse exchange purchase and the reverse exchange guide.
Related questions
Can I identify a property I co-own with someone else?
Only your own interest can be relinquished, and the seller must be you, the same taxpayer who takes the replacement. Name the specific interest you will sell.
Can I change the list after day 45?
No. As with replacement lists, an identification can be revoked or changed only before the end of the 45-day period.
Does the property I identify have to be similar in value?
No value match is required to identify it, but selling for less than the replacement value with less debt can leave you with boot or no deferral on the difference.
Can a property I identify be sold to a relative?
Section 4.02(5) requires transfer to a person who is not you or a disqualified person, and related-party rules in section 1031(f) can also apply.
Do I identify anything if the titleholder holds my old property?
No separate list is needed for the relinquished property in the exchange-first form, because it is the property you deeded to the titleholder.
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.