IRS Releases Favorable Ruling on Like Kind Exchange Programs
The new IRS ruling (201308020) makes it clear that WTP Exchange is permitted under the tax law to provide both Like Kind Exchange (LKE) software and qualified intermediary services. LKE is a common tax-deferred exchange used by businesses.
The Internal Revenue Service (IRS) has released a favorable private letter ruling related to a common tax strategy referred to as a Like Kind Exchange (LKE) program, according to WTP Exchange. The ruling was requested by, and issued to WTP Exchange, an affiliate company of WTP Advisors, a global tax and business advisory firm.
The new IRS ruling (201308020) makes it clear that WTP Exchange is permitted under the tax law to provide both LKE software and qualified intermediary services. “The IRS ruling provides companies with a level of certainty in an uncertain world,” said Ron Hodgeman, tax attorney and partner at WTP Exchange.
Companies are very cautious about implementing tax strategies. An unproven or poorly designed LKE program solution can lead to IRS audits and the assessment of penalties and interest.
“Even though tax-deferred exchanges have been a part of our tax law for over 90 years, we decided to obtain an IRS ruling around our solution to help put our clients at ease,” Hodgeman said.
Under Internal Revenue Code section 1031, no gain or loss is recognized when companies sell business or investment property and acquire property that is like-kind. A transaction that is structured as a tax-deferred exchange is generally referred to as a “like-kind exchange” or an “LKE."
Equipment dealers, car rental companies, and other organizations that routinely dispose of business assets can realize substantial benefits from an ongoing program of exchanges (referred to as an LKE Program).
WTP Exchange is the only firm in the world to offer a fully-integrated LKE program solution, according to the company. In addition to its software, which was built on more than 25 years of LKE program experience, WTP Exchange provides LKE tax consulting services, and Qualified Intermediary (QI) services.
More Rental Operations

Turo and Tesla Take the Next Step Toward Autonomous Car Rentals
The partnership brings Tesla's Full Self-Driving (Supervised) technology into the rental experience, offering a glimpse of how increasingly automated vehicles could change car rental.
Read More →
How Rental Operators Can Navigate Personalized Pricing Rules
As regulators scrutinize the use of customer data in pricing, rental operators need to know whether they can explain why one renter pays more than another.
Read More →
Direct, Broker or Hybrid? How Travel Retailers Source Rental Cars
As travel retailers weigh direct supplier relationships against third-party distribution, rental operators need to understand how those decisions affect their business.
Read More →
How Did This Independent Rental Operator Grow to 170 Vehicles in 4 Years?
With 170 vehicles across three Kentucky locations, Joel Price relies on an overseas team to handle reservations, payments, and after-hours customer service. It's one part of an unconventional approach to growing an independent rental operation.
Read More →
What Does It Take to Succeed in B2B Rentals?
The fundamentals may be familiar to daily car rental operators, but project-based truck rentals put different demands on the fleet and the business.
Read More →
NPR Builds on International Partnerships to Grow Rental Bookings
With Ana Laborde supporting broker development, NPR Auto Group is tailoring distribution strategies, rate packages, and partnerships to grow international reservations across its three brands.
Read More →
Advantage, Sixt Place Among Top Five in Annual Satisfaction Study
While Enterprise and National retain the top spots in JD Power’s 2026 rankings, the latest customer satisfaction results suggest renters can find competitive service beyond the biggest car rental names.
Read More →
The $100,000 Insurance Trap in Exotic Car Rentals
Exotic rental agencies often rely on customers’ personal auto policies to protect six-figure vehicles. But policy language can dramatically change the coverage for vehicles over $100,000 MSRP.
Read More →
The Booking Is Confirmed, But Is Your Customer Ready to Drive?
For international renters, a confirmed reservation doesn’t always mean they’re eligible to drive. Earlier checks can help operators catch documentation and payment issues before the customer reaches the counter.
Read More →
ICRS 2027 Opens Call for Papers
The International Car Rental Show seeks session proposals on the business, operational, and technology issues facing car rental operators. Submissions are due Jan. 15.
Read More →
