A reverse exchange represents a tax deferred transaction in which an Exchanger acquires his Replacement Property before he disposes of his Relinquished Property.
Because the IRS will not allow an Exchanger to exchange into property he already owns, the logistics for a reverse exchange are slightly more complicated than a traditional deferred exchange.
The expanded logistics include the creation the Qualified Intermediary of an Exchange Accommodation Titleholder or (EAT) which is a Limited Liability Company created for the purpose of holding title to one of the properties in the stead of the Exchanger.