The short answer
An exchange accommodation titleholder, or EAT, is the party that holds title to property for you in a reverse or improvement exchange under the safe harbor of Rev. Proc. 2000-37, so the IRS treats it as the owner while your exchange is completed. It cannot be you or a disqualified person, must be subject to federal income tax, and often holds title through a single-member LLC. The written arrangement it holds the property under is a qualified exchange accommodation arrangement, which must wrap up within 180 days.
At a glance
| Who can serve | Not you or a disqualified person, and subject to federal income tax |
|---|---|
| How it holds title | Legal title, a contract for deed, or a single-member LLC that holds title |
| Written agreement | Within five business days after the EAT takes title |
| Time limits | Relinquished property identified within 45 days; everything done within 180 days |
The role was created by a 2000 revenue procedure because the deferred exchange rules do not cover buying first
Rev. Proc. 2000-37 notes that the 1991 deferred exchange regulations do not apply to reverse-Starker exchanges, where replacement property is acquired before the relinquished property is transferred. Taxpayers had been parking property with accommodation parties, and the procedure gave them a safe harbor.
Under section 4.02, an EAT holds qualified indicia of ownership: legal title, other indicia treated as beneficial ownership under commercial law such as a contract for deed, or the interests in a disregarded entity such as a single-member LLC that holds title. If the EAT is a partnership or S corporation, more than 90% of its interests must be owned by persons subject to federal income tax.
You must intend, when the EAT takes title, that the property be part of a section 1031 exchange. You and the EAT sign a qualified exchange accommodation agreement within five business days, both report the EAT as the beneficial owner for federal tax purposes, and the relinquished property is identified within 45 days.
Worked example: parking the replacement warehouse while the apartment building sells
Hypothetical: you find a $2,000,000 warehouse before your apartment building has a buyer. The EAT's single-member LLC takes title on day 0, funded by a bank loan you guarantee and a loan from you, both permitted by section 4.03. You sign the agreement within five business days and lease the warehouse from the LLC while you wait.
By day 45 you identify the apartment building as the relinquished property. It sells on day 120 through a qualified intermediary, and the intermediary uses the proceeds to acquire the LLC's interest or the warehouse for you, well inside the 180 days.
If the building had not sold by day 180, the safe harbor would not apply and ownership would be judged on the facts. Work through the dates with your CPA; see the reverse 1031 exchange guide.
Where it bites: property you already own, the 180 days, and fees
Rev. Proc. 2004-51 says the safe harbor does not apply to replacement property you owned within the 180 days before the EAT took title. Building on land you already own is not covered either; see building on land you already own.
The combined time the relinquished and replacement properties spend with the EAT cannot exceed 180 days. Puts and calls between you and the EAT are allowed only for up to 185 days from its acquisition.
No rule sets the EAT's fee. The procedure warns that the IRS may recast amounts paid under these side arrangements as a fee to the EAT to reflect their economic substance, and the Form 8824 instructions point to both revenue procedures for reporting. For buying a DST first, see reverse exchange into a DST.
Related questions
Can my qualified intermediary also be the EAT?
Yes. Section 4.03 of Rev. Proc. 2000-37 lets an EAT that meets the qualified intermediary requirements also serve as intermediary in the exchange. Its services as EAT do not make it a disqualified person.
Can I manage or improve the property while the EAT holds it?
Yes. The procedure allows you to lease the property, manage it, supervise improvements or act as contractor without losing the safe harbor.
What happens if the exchange takes longer than 180 days?
The safe harbor no longer applies, and whether you or the EAT owned the property is decided under the general benefits-and-burdens analysis rather than the procedure.
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.