An improvement exchange represents a tax deferred transaction in which an Exchanger adds new improvements or construction to his Replacement Property before taking title. The improvement exchange usally requires the creation by 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 the Replacement Property while the improvements are being completed, and before the time the property is deed to the Exchanger.