1031 Exchange Crowdfunding Limitations: What Investors Should Know

The term "1031 crowdfunding" sounds like a perfect marriage: combine the tax-deferral benefits of a 1031 exchange with the accessibility of modern real estate platforms. But here is what many investors do not realize until late in the process: most conventional crowdfunding investments are securities rather than real property, and securities are not eligible replacement property under Section 1031. That disconnect between investor expectations and legal reality is the central limitation in this space. Understanding what actually qualifies, what fees you will pay, and what control you will surrender is essential before committing capital. This guide breaks down the limitations investors need to know, so you can make informed decisions about whether this strategy fits your goals, or whether alternatives like fractional real estate investing fit your situation better.

Disclaimer: The information provided in this guide is for educational purposes only and does not constitute financial, tax, or legal advice. Always consult with a licensed professional before making any financial or investment decisions.

Key Takeaways

• Most conventional crowdfunding investments are not replacement real property. Platforms such as Fundrise, Arrived, EquityMultiple, and Groundfloor issue securities, including nontraded REIT interests, Series LLC membership interests, special-purpose-vehicle LLC interests, and loan-backed instruments. Eligibility depends on the legal and federal tax classification of the specific interest acquired, not on the platform offering it. Direct real-property ownership remains the standard qualifying form, and Delaware Statutory Trusts (DSTs) and Tenancy-in-Common (TIC) arrangements are two fractional structures that may qualify when properly structured.
• DST cost loads must be calculated from the offering documents, not from a rule of thumb. DST offerings can carry acquisition, asset-management, disposition, financing, legal, administrative, reserve, and selling expenses, and those charges vary materially by sponsor and offering. No single percentage applies to all DSTs.
• Accredited-investor status is common in practice but is not universally required by Regulation D. Offerings made under Rule 506(c) must be sold only to verified accredited investors, while Rule 506(b) may include up to 35 sophisticated non-accredited purchasers subject to greater disclosure obligations. Many sponsors nevertheless restrict their offerings to accredited investors as a matter of policy.
• The deadlines create genuine timing risk. The 45-day identification and 180-day acquisition periods generally cannot be extended by agreement, hardship, weekends, or holidays. Limited statutory relief may apply in federally declared disasters, significant fires, terroristic or military actions, and certain combat-zone circumstances.
• Investors surrender day-to-day control for a multi-year hold. DSTs are deliberately non-discretionary under Revenue Ruling 2004-86, and target holds commonly run roughly 5 to 10 years, though the period is offering-specific and generally not a fixed maturity date.

Understanding 1031 Exchange Rules in Crowdfunding Contexts

The confusion starts with terminology. When investors search for "1031 crowdfunding," they often assume any real estate crowdfunding platform can serve as replacement property in a tax-deferred exchange. That assumption is usually incorrect, but the reason matters more than the conclusion.

Direct ownership of qualifying investment or business real estate is the ordinary form of Section 1031 replacement property. Depending on federal tax classification, real property held through a disregarded entity or certain grantor-trust arrangements can also be treated as owned directly by the taxpayer. Two fractional structures are commonly used by exchangers:

• Delaware Statutory Trusts (DSTs): Revenue Ruling 2004-86 holds that the particular DST described in the ruling, with specifically restricted trustee powers, is classified as an investment trust, and that each beneficial owner is treated as owning an undivided interest in the underlying real property. An exchange into an interest in such a trust may qualify if all other Section 1031 requirements are met. The ruling does not establish an exclusive list of qualifying structures.
• Tenancy-in-Common (TIC) arrangements: Structures where multiple investors hold undivided fractional interests in real property. Revenue Procedure 2002-22 sets out the conditions under which the IRS will ordinarily consider an advance ruling request for a TIC arrangement, including a guideline of no more than 35 co-owners. That revenue procedure expressly states that its guidelines are not substantive rules and are not to be used for audit purposes, so the 35-owner figure is an influential structuring standard rather than a statutory maximum.

What generally does not qualify:

• Nontraded REIT shares, such as Fundrise eREIT interests
• Series LLC membership interests, such as many Arrived offerings, where legal title to each home sits in the series entity
• Special-purpose LLC membership interests used by many crowdfunding sponsors
• Loan-backed securities issued by debt platforms such as Groundfloor
• Conventional pooled-fund, corporate, and partnership interests

That last category needs a precise statement rather than a blanket one. A conventional fund interest generally fails because the investor owns an interest in an entity or a security rather than the underlying real property. Pooling by itself is not the disqualifier: a DST also pools multiple investors, and Revenue Ruling 2004-86 treats the beneficial owners of the qualifying grantor trust as owning aliquot interests in its real estate for federal income-tax purposes.

The distinction matters because the IRS treats entity and security interests fundamentally differently from real property. The Tax Cuts and Jobs Act of 2017 limited Section 1031 to qualifying real property for exchanges completed after December 31, 2017. Securities representing real estate do not qualify as real property: they represent ownership in an entity that owns property, which is a critical legal distinction.

For investors exploring how to invest in real estate, understanding this structural difference prevents costly mistakes when tax planning.

The 45-Day and 180-Day Deadlines

The timeline requirements for 1031 exchanges create genuine pressure points that fractional structures can either ease or worsen.

Critical deadlines:

• 45 calendar days: From the transfer of the relinquished property, the taxpayer must identify potential replacement property in a signed written document delivered to the qualified intermediary or another recipient permitted by Treasury Regulation Section 1.1031(k)-1. A qualified intermediary is the usual and most prudent recipient, but the regulations also contemplate delivery to another qualifying person involved in the exchange who is not the taxpayer or a disqualified person.
• 180 calendar days: Replacement property acquisition must generally occur by the earlier of 180 days after the transfer or the due date, including extensions, of the taxpayer's federal return for the year of transfer.

These are calendar-day rules, and they generally cannot be extended by agreement, hardship, weekends, or holidays. Limited relief may apply under Revenue Procedure 2018-58 and related IRS guidance for federally declared disasters, significant fires, terroristic or military actions, combat-zone service, or other specifically authorized circumstances. Relief is not automatic, and whether and how the deadlines are postponed depends on the applicable statutes and the specific IRS guidance issued.

The 45-day identification window creates particular challenges. Investors who sell properties quickly may find themselves scrambling to identify replacement options. Prepackaged DST offerings can help here: 1031 Crowdfunding states that some clients can complete DST placements within several days, though that should be read as a company-specific capability rather than a general industry standard.

What happens if you miss a deadline:

An untimely identification or acquisition causes the affected replacement property to fail Section 1031 treatment. If no qualifying replacement property is timely acquired, the deferred exchange generally fails. In a multi-property or partial exchange, however, qualifying portions may still receive nonrecognition treatment: a taxpayer may close on fewer than all identified properties, may receive taxable boot, and may have satisfied identification for a property actually acquired within the identification period.

When gain is recognized, it is the realized gain, generally the amount realized less adjusted basis and selling costs, not the gross sale proceeds. Part of that gain may be unrecaptured Section 1250 gain, which is subject to a maximum federal rate of 25%, and other depreciation-recapture rules may treat some amounts as ordinary income.

Investors sometimes see illustrative dollar examples of a failed exchange. Treat them cautiously: the outcome depends on adjusted basis, selling costs, whether accumulated depreciation is already included in the stated gain, the federal capital-gain bracket, the net investment income tax, state and local taxes, suspended loss carryforwards, and filing status. Any figure presented without those assumptions stated is not verifiable.

On the mechanics of holding proceeds: the taxpayer must avoid actual or constructive receipt of the sale proceeds. Most deferred exchanges use a qualified intermediary engaged before the relinquished-property transfer, but Treasury regulations provide several safe harbors, including qualified escrow accounts and qualified trusts, so a qualified intermediary is not the only legally permissible structure. The regulations restrict the taxpayer's rights to receive, pledge, borrow, or otherwise obtain the benefits of the proceeds; they do not impose a universal federal rule that every intermediary must hold each exchanger's funds in a separate segregated account. Fund-security protections such as segregated or qualified escrow accounts, fidelity coverage, and dual authorization depend on the exchange agreement, the custodian, applicable state law, and the intermediary's own practices.

Fee Structures and Whether They Erode the Benefit of Deferral

The economics of DST investments deserve scrutiny. Tax deferral is valuable, but embedded costs reduce the capital actually working for you, and in some scenarios they can outweigh the benefit.

Fee categories to identify in the offering documents:

1031 Crowdfunding's educational material identifies the common categories: acquisition, asset management, disposition, financing, legal, administrative, reserve, and selling expenses. It also emphasizes that these charges vary by sponsor and by offering. Aggregate compensation can differ substantially based on leverage, property type, sponsor, distribution channel, and broker-dealer arrangements, so any single "typical" percentage has limited explanatory value.

Rather than a rule of thumb, the aggregate load is established by the individual private placement memorandum, and the components that determine it generally include:

• Total offering load as a percentage of gross equity
• Property purchase price versus investor equity
• Selling compensation
• Sponsor acquisition and financing fees
• Ongoing asset-management and property-management charges
• Disposition fees
• Related-party payments
• Reserves
• Projected investor equity at closing

Comparing fees across platforms:

Comparisons between DSTs and non-qualifying platforms are often made on inconsistent bases, because an upfront transaction load and an annual management fee are not the same thing. Put all costs on a common basis (upfront, annual, property-level, and disposition) and model them over the same expected holding period. For reference, Fundrise currently discloses a 0.15% annual advisory fee plus a 0.85% annual management fee for its relevant real estate funds, and Arrived discloses AUM fees of roughly 0.1% to 0.30% per quarter, equivalent to roughly 0.4% to 1.2% annually, with offerings also bearing property-level and transaction expenses. Other platforms use materially different structures.

When deferral may not be worth the cost:

Whether DST costs outweigh the value of deferral is taxpayer-specific and offering-specific. It cannot be determined reliably from exchange size or ordinary marginal tax bracket alone, and an ordinary-income bracket does not by itself determine the tax on long-term gain or unrecaptured Section 1250 gain. A valid analysis requires the actual deferred gain rather than gross proceeds, plus federal gain character, state tax, the net investment income tax, basis, debt replacement, expected return, fee timing, hold period, the value you place on liquidity, and whether you intend to keep exchanging or hold until death.

For investors weighing options, understanding cash flow versus appreciation dynamics helps determine whether the trade-off makes sense for a specific situation.

Liquidity Challenges and Control Limitations

DST investments are illiquid. This is not a minor consideration: it is a defining characteristic that shapes which investors these structures suit.

Hold periods: DSTs commonly target multi-year holds, often roughly 5 to 10 years, and offering-specific terms vary. A sponsor's target hold is not a binding minimum or a maturity date. A property may sell earlier or remain unsold considerably longer.

Secondary market: DST interests have no liquid, centralized, transparent public trading market. Limited specialized channels do exist; Realized, for example, advertises a process for marketing existing DST interests to potential buyers. Execution is uncertain and may require a discount, sponsor consent, purchaser qualification, and transfer documentation.

The comparison people usually draw here needs care. Against publicly traded stocks, the illiquidity contrast is fair. Against other private crowdfunding securities it is not: FINRA identifies illiquidity, limited valuation information, and the absence of transparent markets as common risks of private placements generally. Some platforms have introduced limited resale mechanisms, and Arrived, for instance, operates a secondary market with its own purchase and sale limits, but these are not equivalent to a liquid securities exchange.

Operational restrictions under Revenue Ruling 2004-86:

The trust powers in Revenue Ruling 2004-86 are deliberately narrow, because those restrictions are what preserve the trust's classification as an investment trust rather than a business entity. Under the facts of the ruling, the trustee may not:

1. Accept additional capital contributions
2. Exchange or purchase new property, other than permitted short-term investment of cash pending distribution
3. Renegotiate the terms of the existing acquisition debt or borrow new funds
4. Renegotiate the existing lease or enter into new leases, except in the event of the tenant's bankruptcy or insolvency
5. Make more than minor nonstructural modifications to the property, unless otherwise required by law
6. Retain cash beyond reasonable reserves, as available cash less reserves must be distributed on a current basis, quarterly

The trust in the ruling also held a single property, terminated upon its disposition, and could not reinvest the proceeds. A multi-property offering requires separate analysis of its trust documents and tax structure. The popular "Seven Deadly Sins" label is industry shorthand, not terminology used by the IRS, and the ruling applies to the specific fact pattern it describes.

What this means for investors:

DST investors generally surrender day-to-day management authority and cannot direct ordinary leasing, financing, improvement, or disposition decisions. That is a defining structural characteristic. It is not accurate, however, to say every DST investor has literally zero voting, consent, removal, amendment, or enforcement rights: those depend on the trust agreement and the private placement memorandum, and the ruling's restrictions primarily limit trustee powers necessary to preserve the trust's federal tax classification.

TICs differ on this point. Revenue Procedure 2002-22 expressly contemplates co-owner voting on major matters, including unanimous approval for certain leases, indebtedness, sale, and management arrangements.

Real estate attorney Andy Sirkin identifies a similar cluster of considerations in sponsored TIC and DST arrangements: loss of operational control and the illiquidity that follows from it, reliance on sponsor oversight, the cost of sponsor compensation, and the possibility that an over-subscribed or under-subscribed offering leaves the exchanger unable to close in time.

For investors who value flexibility, fractional ownership structures that do not carry these restrictions may offer a different balance of accessibility and participation.

The Accredited Investor Question

Most broadly marketed DST private placements are restricted to accredited investors, particularly when offered under Rule 506(c). But market practice and legal requirement are not the same thing, and the distinction matters for anyone who has been told the door is categorically closed.

• Under Rule 506(c), all purchasers must be accredited and the issuer must take reasonable steps to verify that status.
• Under Rule 506(b), an offering may include up to 35 non-accredited purchasers who meet the applicable sophistication standard, though the disclosure burden on the issuer is substantially greater.
• Individual sponsors and marketplaces commonly limit offerings to accredited investors as a contractual or offering-policy matter.

Accreditation categories:

The familiar tests are $200,000 in annual income ($300,000 joint) for the past two years with a reasonable expectation of continuation, or $1,000,000 in net worth excluding the primary residence. Those are no longer the complete individual definition. Individuals may also qualify through specified professional credentials, including Series 7, Series 65, and Series 82 licenses, and additional categories cover knowledgeable employees and qualifying entities. The picture is therefore not a simple split between wealthy investors and everyone else, even though accredited-only offerings do materially restrict access.

Minimum investment thresholds:

Beyond accreditation, DST minimums are offering-specific. Current 1031 Crowdfunding educational material states that cash minimums can be as low as $25,000 and that many minimums fall between $25,000 and $100,000, with 1031 exchange minimums often around $100,000.

Non-accredited investors generally face fewer prepackaged, hands-off replacement-property choices. They are not, however, limited to actively managing property themselves or paying the tax: direct property can be professionally managed, some properly structured TIC arrangements may remain available, and Rule 506(b) may permit a limited number of sophisticated non-accredited purchasers. Whether accreditation is required depends on how the particular interest is offered under securities law, not on any intrinsic tax rule.

Due Diligence Beyond Sponsor Marketing

Sponsor quality varies in the DST space, and DST interests offered as private placements are not subject to the public reporting and Investment Company Act framework that governs mutual funds and ETFs. Regulators also do not merit-review whether an acquisition is economically attractive.

That is not the same as an absence of oversight. FINRA identifies obligations covering reasonable investigation and due diligence, Regulation Best Interest or suitability, supervision, communications with the public, private-placement filings, conflicts and selling compensation, and evaluation of the issuer, management, assets, claims, and use of proceeds. Private-placement status means reduced public disclosure and no regulatory approval of investment merit, not unregulated activity.

Critical due diligence factors:

• Sponsor track record: Marketing claims of unbroken performance depend on specifics such as the inception date, the number of realized programs, whether results are stated gross or net of fees, how open and impaired programs are treated, and the source documents behind any claim about losses, foreclosures, or suspended distributions. A phrase like "no capital losses since inception" can be defined in different ways.
• Property selection criteria: How a sponsor identifies and underwrites properties, and what share of reviewed deals actually closes, says a great deal about process discipline.
• Fee transparency: Whether all fees are set out clearly upfront or appear only in the operating agreement is a core consideration. Sponsor selection frameworks are a useful starting checklist.
• Exit strategy: How a sponsor has historically handled dispositions is equally informative.

The importance of data in real estate investing applies doubly here. Investors without institutional research capabilities face genuine challenges assessing sponsor quality.

mogul's approach to property selection reflects the level of rigor that any real estate investment decision deserves. The company states that fewer than 1% of reviewed properties pass its diligence process.

Tax Implications Beyond Deferral

Common misconception: 1031 exchanges eliminate taxes. They do not. Adjusted basis generally carries into the replacement property, and gain can be recognized on a later taxable disposition unless another nonrecognition or basis rule intervenes.

What is actually deferred:

• Federal long-term capital gain, taxed at 0%, 15%, or 20% depending on taxable income and filing status, with the 3.8% net investment income tax potentially applying as well
• Unrecaptured Section 1250 gain, subject to a maximum federal rate of 25%, with other recapture amounts potentially taxed as ordinary income
• State income taxes where applicable

The basis adjustment at death:

Under current federal law, qualifying property acquired from a decedent generally receives a basis equal to its estate-tax value, ordinarily fair market value at the date of death or, where properly elected, the alternate valuation date. This commonly eliminates the decedent's previously deferred built-in gain for federal income-tax purposes. It is not unconditional: estate-inclusion and qualification requirements, consistent-basis rules, possible estate tax, state variations, post-death appreciation, and future legislative change all bear on the outcome.

The estate-planning value is greater for investors who both intend and are financially able to hold qualifying property for life. That conclusion should rest on individual estate, liquidity, health, diversification, and tax circumstances rather than on a fixed age threshold.

Understanding tax benefits of real estate helps investors evaluate whether 1031 exchange complexity fits their overall wealth-building strategy.

Current Market Conditions

Two developments are frequently conflated and should be kept apart.

First, certain nontraded REIT products reported substantial NAV declines or restricted investor activity during 2025 and 2026, with declines in the range of 23% to 32% reported for some offerings. Those developments illustrate broader private real estate risk, but REIT offerings are not DST offerings, and REIT losses are not evidence about DST market performance.

Second, the DST market itself expanded during the same period. Approximately $8.41 billion of DST equity was raised in 2025, and by mid-2026 available DST equity reportedly reached a record of roughly $3.9 billion across about 100 offerings. Investors can still face offering-specific shortages based on required debt replacement, equity amount, property type, geography, risk tolerance, or closing timing, but a broad claim that overall DST inventory has tightened is inconsistent with current market data.

As of July 2026, Section 1031 remains in force for real property held for productive use in a trade or business or for investment, subject to the statutory requirements. Discussions around tax reform resurface frequently, and 1031 exchanges are typically part of broader conversations about federal revenue and capital gains policy.

Expanded inventory may increase investor choice and negotiating leverage. It does not automatically mean underlying assets are favorably priced: sponsors may maintain pricing, increase selling compensation, alter leverage, or simply leave offerings open longer. Favorable pricing must be established through property-level valuation, debt, fee, and comparable-sales analysis.

Why mogul Offers a Different Path

For investors who do not need immediate Section 1031 deferral and want property-level real estate exposure without DST structural constraints, mogul is worth evaluating. mogul is a fractional real estate platform club founded by former Goldman Sachs executives, built around professionally vetted and managed single family rentals that generate monthly income and long-term appreciation through transparent, asset-level ownership.

What differentiates mogul:

• Underwriting rigor: mogul describes its underwriting process as institutional-grade. The founding team comprises former Goldman Sachs real estate professionals with more than $10 billion in collective deal experience, and the company states that fewer than 1% of reviewed properties pass its diligence process.
• Property-specific fractional ownership: Each investment represents a fractional membership interest in a state-registered LLC that owns the individual property, rather than an interest in a blind pool spanning many assets.
• Property-level income and appreciation participation: Investors hold proportional rights to rental income and to appreciation proceeds on an eventual sale of the property, subject to property performance and offering terms.
• Potential pass-through tax treatment: The LLC structure may provide investors with pass-through tax reporting and depreciation-related tax benefits, depending on the offering, applicable loss-limitation and at-risk rules, and each investor's circumstances.
• Monthly distributions once operational: Once a property is operational, investors may receive monthly dividends from their proportional share of net rental income, subject to property operations, expenses, reserves, and offering terms.
• Governance rights on major decisions: mogul investors receive governance rights on specified major property decisions, generally through supermajority voting, while professional managers handle routine operations, which keeps the experience headache-free.
• Secondary market: mogul is developing a secondary market intended to let eligible investors list shares using fair-market-value estimates based on monthly third-party appraisal data.
• Open to accredited and non-accredited investors: mogul accepts both accredited and non-accredited investors, subject to onboarding, KYC, and other eligibility requirements.
• First $10k protection for new members: mogul covers up to $10k in losses for qualifying new members under its first-year protection promotion, subject to the program terms.

mogul today reflects that positioning as a leading real estate platform: $40M+ in assets invested through the platform, 13,000+ investors, an average investment of roughly $10k, and an 18.8% average IRR across platform assets to date.

On costs: mogul uses a fee-efficient structure and does not charge a traditional annual AUM fee against invested equity. Its disclosed fees include a 3% one-time platform fee, a possible additional 2% setup fee, and an ongoing 2.5% fee on collected rental income, each stated upfront.

mogul's offerings are structured as property-specific LLC interests built for direct participation in individual homes rather than as 1031 exchange replacement property, since securities and partnership interests sit outside Section 1031 treatment. Investors whose immediate objective is deferring gain from a recent property sale typically use a qualifying exchange structure for that portion of their capital.

For investors who do not need immediate Section 1031 deferral, mogul offers an accessible property-level investment structure with straightforward eligibility and meaningful say in major decisions. How that compares with a DST exchange on an after-tax basis depends on your tax liability, fees, holding period, property performance, and liquidity preferences. For those focused on building wealth through real estate rather than specifically on deferring a pending gain, that comparison often favors the simpler structure.

Disclaimer: The information provided in this guide is for educational purposes only and does not constitute financial, tax, or legal advice. Always consult with a licensed professional before making any financial or investment decisions.

Frequently Asked Questions

Can I use a standard real estate crowdfunding investment for a 1031 exchange?

Generally no. Conventional crowdfunding investments such as nontraded REIT shares, LLC and Series LLC membership interests, and loan-backed securities are entity or security interests rather than replacement real property. Direct real property ownership is the standard qualifying form, and properly structured DSTs and TICs are two fractional alternatives that may qualify. Eligibility turns on the legal and federal tax classification of the specific interest you acquire, not on the platform offering it, so speak with a qualified tax professional before assuming any vehicle qualifies.

What happens to my deferred taxes if I hold DST investments until death?

Under current federal law, qualifying property included in a decedent's estate generally receives a basis equal to its estate-tax value, ordinarily fair market value at the date of death or an elected alternate valuation date. This commonly eliminates the decedent's previously deferred built-in gain for federal income-tax purposes, subject to estate-inclusion requirements, consistent-basis rules, possible estate tax, state variations, and future legislative change. The strategy is most relevant for investors who both intend and are financially able to hold the property for life.

Are there alternatives to DSTs for investors who are not accredited?

Non-accredited investors generally face fewer prepackaged, hands-off replacement-property options, but they are not limited to self-management or paying the tax. Direct property can be professionally managed, some properly structured TIC arrangements may remain available, and Rule 506(b) offerings may include a limited number of sophisticated non-accredited purchasers subject to greater disclosure requirements. Whether accreditation is required depends on how the interest is offered under securities law. For those prioritizing real estate investing with limited capital, fractional ownership platforms that do not require accreditation may offer broad accessibility to income-producing properties.

What professional advisors do I need for a 1031 exchange?

Most deferred exchanges involve a qualified intermediary engaged before the relinquished-property transfer, along with a CPA or tax attorney familiar with Section 1031 and, where a private placement is involved, a real estate or securities attorney to review the offering documents. Note that the regulations also permit other safe harbors, including qualified escrow accounts and qualified trusts, so an intermediary is the dominant method rather than the only permissible one. Professional costs vary widely with the number of properties, whether the structure is a reverse or improvement exchange, the extent of document review, and multi-state complexity, so a single quoted range rarely reflects an individual situation. Given state conformity rules, including California's continuing Form FTB 3840 reporting for deferred California-source gain, state-specific tax advice is essential when exchanging across state lines.

How do I evaluate whether a DST investment makes economic sense versus paying capital gains?

Model your specific scenario: calculate the tax that would be due on a taxable sale, using your actual deferred gain rather than gross proceeds, the character of that gain, any unrecaptured Section 1250 gain, the net investment income tax, and state tax. Then weigh that against the DST's aggregate cost load as set out in the offering documents, plus the opportunity cost of that drag over the expected hold period, and weigh how much you value liquidity and whether you intend to keep exchanging or hold until death. Use mogul's real estate calculator to model property-level returns under different operating, financing, and holding-period assumptions. Comparing a taxable sale with a DST-based exchange requires a separate tax model and advice from a qualified tax professional.