1031ing multiple properties with different LLC's.

[Luke G.]

I've asked around in my real estate circles and nobody seems to have a definitive answer (including my CPA or the 1031 intermediary). I'm currently selling 2 properties owned by 2 different LLC's (I'm the sole owner of both). Am I allowed to do a 1031 exchange into one property following the sale of these two properties even though they're owned by different entities? I'm fine eating the tax if I have to, but if I'm allowed to 1031 I'm trying to in this case. I just want to make sure I'm not going to get hit with an unexpected tax bill later.

[Jon Taylor]

Yes, likely, depending (how do you like that answer?).

The IRS is concerned about the tax-paying entity being the same on the relinquished and replacement side of the exchange. If the LLC is a *disregarded* entity, and the taxes and income flow through to you, individually, then you are the taxpayer performing the transaction, and it's likely that you can combine the exchange.

It's an accounting question that the accountants should answer. The 1031 intermediaries, like myself, have seen a lot of transactions and can comment on how they've seen accountants advise. 

@Dave Foster will chime in here. He may disagree with me, and if so, I'd take his advise :)