Qualified Exchange Accommodation Agreement (QEAA)

Exchanger (Taxpayer): [Name] · Exchange Accommodation Titleholder (EAT): [Name/Entity] · Property: [Address] · Date: [Date]

1. Purpose

This Agreement facilitates a "reverse" like-kind exchange under IRC Section 1031 and Revenue Procedure 2000-37, under which EAT will acquire and hold title to the property described above as an accommodation for Exchanger, pending Exchanger's disposition of its relinquished property.

2. Acquisition by EAT

EAT will take title to the property using funds provided by Exchanger [via a loan from Exchanger or a qualified intermediary], for the purpose of "parking" this property until the exchange is completed.

3. Holding Period

EAT will hold qualified indicia of ownership of the property for no longer than 180 days, consistent with the safe harbor period established under Rev. Proc. 2000-37, unless the parties agree the transaction will proceed outside the safe harbor with appropriate additional risk disclosure.

4. Management During Holding Period

[State who manages the property (typically Exchanger, via a management agreement or lease-back), and who bears the economic benefits/burdens during EAT's holding period.]

5. Transfer to Exchanger

Upon Exchanger's completion of the exchange (identification and closing of the relinquished property within the applicable exchange periods), EAT will transfer the property to Exchanger [or Exchanger's designee], completing the exchange.

6. Fees

Exchanger will pay EAT a fee of [Amount] for accommodation services, plus reimbursement of costs incurred while holding title.

7. Risk and Indemnification

[Allocate responsibility for property-related risks — taxes, liability, casualty — during the holding period, typically remaining with Exchanger via a triple-net lease-back arrangement.]

Exchanger: ______________________ Date: ____________ EAT: ______________________ Date: ____________

*This document is provided for informational and educational purposes only and does not constitute legal or tax advice. Reverse exchanges are one of the more technically demanding forms of 1031 exchange, with a strict 180-day safe harbor and specific IRS requirements for the EAT's role — this arrangement should be set up with an experienced qualified intermediary and tax counsel before any property changes hands, not drafted from a template alone.*