Worksheets · Timeline
1031 Exchange Timeline Worksheet
One page from listing to closing the replacement: every step of a deferred exchange, who does it, the document it produces and a date column to fill in as you go.
What this worksheet does
A deferred exchange is a sequence of documents in a fixed order, and the order is what the regulation tests: the exchange agreement before the sale closes, the proceeds to the intermediary and never to you, the written identification by day 45, the replacement received by day 180. This worksheet lists every step from listing to the replacement closing, with the person who owns it and the paper it produces.
Fill the date column as you go and the sheet becomes the record your CPA needs for Form 8824. The intermediary's own documents are explained on working with a qualified intermediary; the week-by-week plan for the identification window is the 45-day plan.
The timeline
Seller, agent, qualified intermediary (QI), CPA, advisor, lender, title. Write the date each document was signed or delivered, not the date it was planned.
| # | Step | Who | Document produced | Date | Done |
|---|---|---|---|---|---|
| Before listing | |||||
| 1 | Confirm the property is held for investment or business use and that the entity on the deed is the one that will buy the replacement. | CPA, attorney | Memo on the holding purpose, the vesting and the adjusted basis | ||
| 2 | Estimate the gain, the depreciation recapture and the tax on a straight sale, so the exchange has a number to beat. | CPA | Gain estimate (the exchange calculator gives a first pass) | ||
| 3 | Engage the qualified intermediary; confirm it is not a disqualified person and how it holds funds. | Seller, advisor | Engagement letter, fee schedule, confirmation of a segregated account | ||
| Listing to closing the sale | |||||
| 4 | List the property with an exchange cooperation clause in the listing and the purchase agreement. | Agent, attorney | Listing agreement; purchase agreement with the cooperation clause | ||
| 5 | Sign the exchange agreement and assign the purchase agreement to the intermediary; notify the buyer in writing. All before closing. | QI, seller | Exchange agreement; assignment; notice of assignment to the buyer | ||
| 6 | Close the sale. Proceeds wire to the intermediary; nothing to the seller. Day 0. | Title, QI | Settlement statement naming the intermediary as payee; any state withholding form | ||
| 7 | Record day 0 and compute day 45, day 180 and the tax-return due date for the sale year. | Seller, advisor | Deadline sheet (the deadline calculator) | ||
| Days 1 to 45: identification | |||||
| 8 | Shortlist replacements; tour properties; obtain memoranda for any trust interest and run the fee worksheet. | Advisor, seller, agent | Shortlist with values; fee worksheets | ||
| 9 | Sign and deliver the identification letter to the intermediary before midnight on day 45; keep the acknowledgement. | Seller | Identification letter and delivery receipt | ||
| Days 46 to 180: acquisition | |||||
| 10 | Sign the replacement purchase agreement with a cooperation clause, or the subscription documents for a trust interest. | Seller, agent, advisor | Purchase agreement, or subscription agreement and purchaser questionnaire | ||
| 11 | Arrange any replacement loan; check that value, equity and debt are replaced. | Lender, CPA | Loan commitment; replacement test sheet (the requirements calculator) | ||
| 12 | Assign the replacement contract to the intermediary and notify the seller of the replacement in writing; direct the intermediary to fund. | QI, seller | Assignment; notice of assignment; written disbursement direction | ||
| 13 | Close the replacement by day 180 or the return due date, whichever is earlier. The intermediary wires; title records the deed, or the trust issues the interest. | Title, QI, trust's closing agent | Settlement statement; deed, or confirmation of the beneficial interest | ||
| After closing | |||||
| 14 | File Form 8824 with the return for the sale year; attach the gain statement if more than one property was given up or received. | CPA | Form 8824; statement; the identification letter and both settlement statements kept with the return | ||
| 15 | Carry the basis into the replacement and restart the depreciation schedule. | CPA | Basis worksheet; depreciation schedule | ||
Worked example (hypothetical)
An imaginary 2026 exchange of a $1,000,000 rental with round figures. Only the order matters; your own dates belong in the column above.
| Step | Date | Note |
|---|---|---|
| 1 and 2 | January 5 | CPA confirms the rental qualifies and estimates the tax on a straight sale. |
| 3 | January 12 | Intermediary engaged; segregated account confirmed in writing. |
| 4 | January 15 | Listed with the cooperation clause; under contract February 20. |
| 5 | March 3 | Exchange agreement, assignment and buyer notice signed a week before closing. |
| 6 and 7 | March 10 | Closing; $1,000,000 wired to the intermediary. Day 45 is April 24, day 180 is September 6 (a Sunday), the return is due April 15, 2027. |
| 8 and 9 | April 20 | Identification letter delivered on day 41: two buildings and one trust interest. |
| 10 and 11 | May 15 and June 30 | Replacement contract signed; loan commitment received. |
| 12 and 13 | August 14 | Assignment and notice to the seller; the intermediary funds; the replacement closes on day 157, with the trust on the list unused. |
| 14 and 15 | April 2027 | Form 8824 filed with the 2026 return; basis carried into the replacement. |
Had the August closing failed, the trust identified on April 20 could have taken the full $1,000,000 inside the remaining days. Run the real dates with your intermediary and CPA; the order is the part that cannot bend.
How the numbers are calculated
The intermediary's role is defined in Reg. section 1.1031(k)-1(g)(4): a person who is not you and not a disqualified person, who enters a written exchange agreement with you and, under it, acquires the relinquished property from you, transfers it to the buyer, acquires the replacement property and transfers it to you. The regulation lets all of that happen by assignment: you assign your rights under each contract to the intermediary and every party to that contract receives written notice of the assignment on or before the transfer. That is why steps 5 and 12 each produce an assignment and a notice.
The order is fixed by paragraph (g)(6). The exchange agreement must expressly deny you any right to receive, pledge, borrow or otherwise benefit from the money before the exchange period ends, with narrow exceptions after day 45 if nothing was identified or after you have received everything you identified. An agreement signed after the sale cannot do that, and proceeds that touch you on the way are taxable. The identification in step 9 must be written, signed and delivered before midnight on day 45; the identification planner is the form.
Form 8824 ties the dates together: line 4 is the transfer date, line 5 the identification date, line 6 the receipt date, and the instructions state the 45-day limit and the rule that the replacement must be received by the earlier of day 180 and the due date of the return for the sale year including extensions. A sale late in the year therefore needs an extension filed to keep the full 180 days. If more than one property was given up or received, the instructions ask for a statement showing the gain computation, which is step 14's attachment.
Who does what: you sign; the agent writes the cooperation clause into the contracts; the intermediary drafts the exchange agreement, assignments and notices and holds the money; the CPA estimates the gain, tracks the basis and files the form; the advisor sources the replacement, including any trust interest; the lender commits the replacement loan; the title or escrow company disburses on the intermediary's written direction. For a trust interest the title company drops out and the trust's closing agent takes the wire; see the DST closing process.
Questions about this worksheet
What if the sale already closed and the proceeds came to me?
Then there is no exchange to document: once you have the money, the regulation treats the sale as taxable, and signing an exchange agreement afterwards does not undo it. Step 5 has to happen before step 6. Choosing the intermediary early is covered on how to choose a qualified intermediary.
Does the buyer of my property have to agree to the exchange?
No. The buyer receives written notice that the contract has been assigned to the intermediary and closes as usual; the cooperation clause in the purchase agreement simply obliges them not to obstruct it. The clause itself is on the exchange cooperation clause.
Can my CPA or attorney be the intermediary?
Not if they have acted as your agent in the two years before the sale, which makes them a disqualified person under paragraph (k) of the regulation. The same test catches your real estate agent. See attorney, CPA or agent as intermediary.
What if day 180 falls after my tax return is due?
The exchange period ends on the earlier of day 180 and the due date of the return for the sale year, including extensions, so a late-year sale needs an extension to keep all 180 days. The mechanics are on keeping the 180 days with an extension.
Where does a DST fit in this timeline?
Between steps 10 and 13: the subscription documents replace the purchase agreement, the intermediary wires to the trust's closing account, and the trust delivers your interest, often within days of a complete file. The sequence is on how quickly a DST can close.
Which of these dates go on Form 8824?
Line 4 asks for the date you transferred the relinquished property, line 5 the date you identified the replacement in writing, and line 6 the date you received it. The sheet's date column is those three plus the paper trail behind them.
Sources
Figures checked on October 8, 2026. Rates and thresholds change each year; this page is general information, not tax or legal advice.
- Treasury Regulation section 1.1031(k)-1(g)(4), qualified intermediaries; (g)(6), restrictions on the taxpayer's receipt of money; (k), disqualified persons
- Internal Revenue Code section 1031(a)(3), identification and receipt requirements
- IRS, Instructions for Form 8824 (lines 4 to 6; the 45-day and 180-day limits)
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