|
DST Structure |
TIC Structure |
| IRS Guidance |
Rev. Rul. 2004-86 |
Rev. Proc. 2002-22 |
| Number of Investors |
Up to 499 |
Up to 35 |
| Ownership |
Percentage of beneficial ownership in a DST that owns real property |
Undivided tenant in common interest in real property |
| Investors receive property deed |
No |
Yes |
| Investors Form Single Member LLC |
No |
Yes (generally) |
| Major Decision Approval |
No voting rights |
Equal voting rights and unanimous approval required |
| Number of Borrowers |
One (the DST) |
Up to 35 |
| Bankruptcy Remote |
Yes |
No (Yes if using a single member LLC) |
