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The Big Picture
Two clocks start the day your sale closes (Day 0). They run simultaneously, not back-to-back:
- 45-day clock — Written identification of replacement(s) delivered to QI
- 180-day clock — Replacement property acquisition complete
Both deadlines are absolute. Calendar days. No weekends/holidays adjustment. No extensions except federal disaster areas.
The Full Timeline
Day −14 to −7
Engage qualified intermediary
Select QI, review exchange agreement, coordinate with your attorney. QI inserts assignment language into your sale contract.
Day 0
Relinquished property closing
Sale closes. Proceeds wire from closing agent directly to QI's segregated exchange account. Both the 45- and 180-day clocks start today.
Days 1–44
Identification window (active research)
Tour properties, negotiate offers, do due diligence. Ideally go under contract on your top choice before Day 45.
Day 45 · midnight
Identification deadline (HARD STOP)
Signed written identification must be received by QI before midnight. After Day 45 you can't add, drop, or swap properties on your list. Calendar days, not business days.
Days 46–179
Exchange period (contract & close)
Finalize contract on an identified property, complete financing, do final inspections, clear contingencies.
Day 180 · midnight
Replacement closing deadline (HARD STOP)
Replacement property closing must complete by midnight Day 180. QI wires funds to closing. You take title. No extensions.
Day 180+
Post-exchange
QI provides exchange closing statement. You file Form 8824 with that year's tax return. New basis, carryover depreciation, and any boot are reported.
Day 45 Pitfalls
- Delivery to QI, not intent. The identification must be received by the QI before midnight — not mailed, not signed, not decided.
- Calendar days. Day 45 lands on a Sunday? It still expires Sunday midnight.
- Unambiguous description. “A property in Dallas” fails. “123 Main St, Dallas, TX 75201” passes.
- QI, not your agent. Must go to the QI. Your attorney or real estate agent can't accept it.
Day 180 Pitfalls
- Counted from Day 0, not Day 45. The 180 days includes the identification period. After Day 45 you have 135 days, not 180 more.
- Tax return due date rule. If your tax return is due before Day 180 and you haven't filed an extension, the exchange must complete by the earlier date.
- Weekend/holiday confusion. Day 180 is Day 180. No shifting to the next business day.
Tax Return Timing Trap
Example: Sale closes November 15, 2026.
- Day 45 = December 30, 2026
- Day 180 = May 14, 2027
Your 2026 tax return is normally due April 15, 2027 — before Day 180. Two options:
- Option A: File by April 15 reporting the exchange (only works if replacement has closed).
- Option B: File Form 4868 extension before April 15. Return due October 15, well after Day 180.
Miss the extension and try to close May 14? The exchange is voided and the whole year's gain becomes taxable on the return you already filed. Expensive lesson.
Disaster Extensions
If your relinquished or replacement property is in a federally-declared disaster zone, deadlines automatically extend under Revenue Procedure 2018-58. Always verify at irs.gov/disaster-relief before relying on an extension.
Reverse Exchange Timeline
Reverse exchanges have a parallel 180-day structure:
- Day 0: EAT (Exchange Accommodation Titleholder) takes title to one property
- Day 45: Identify the relinquished property in writing
- Day 180: Complete sale and unwind the EAT
Plan backwards. The entire exchange takes 4–6 months elapsed. Planning 3+ months before your target sale date is the comfortable pace.