Libin Zhang (Fried Frank, New York), Like-Kind Exchanges on Mars and Beyond, 192 Tax Notes Fed. 253 (July 13, 2026):
On June 12, 2026, Space Exploration Technologies Corp. (SpaceX) went public in the largest IPO in history. While SpaceX’s artificial intelligence technologies account for $26.5 trillion (93%) of its $28.5 trillion total addressable market, the company also has a branch engaged in Falcon rocket launches and Starlink satellite services.
The goal of SpaceX’s space branch is to elevate humanity to a Kardashev Type II civilization, but for now, the company plans to “build infrastructure in the Earth’s orbit, and potentially on the Moon, Mars and beyond.” CEO Elon Musk received some restricted stock with a vesting milestone of SpaceX’s “establishment of a permanent human colony on Mars with at least one million inhabitants.”
A permanent human colony on Mars (and beyond) presents opportunities for the real estate industry and real estate advisers. This article examines like-kind exchanges under section 1031, which has different rules for real estate located outside the United States. It also explores the potential of lunar qualified Opportunity Zones and whether the tax law should be adjusted to accommodate special relativity and limitations imposed by the speed of light.
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