Our Virtual Family Office Specialist, Jay Frank, along with the advisor and CPA, developed a coordinated multi-part strategy using Section 1031, Section 721, and Qualified Opportunity Zone (QOZ) planning:
1. 1031 Exchange
- Exchanged $12M in zero-basis factory real estate into institutional-quality DST multifamily properties
- Acquired non-recourse debt at the DST level, creating $12M of new depreciable basis
- Began receiving ~4.5% cash flow with significant tax efficiency due to depreciation
- Locked in tax deferral on ~$5M tax liability
2. 721 Exchange (UPREIT)
- After 2–3 years, DST interests are eligible to convert into REIT operating partnership units
- Achieved diversification, liquidity (quarterly), and partial tax-free redemptions over time
- Allowed for long-term income, estate planning flexibility, and continued tax deferral
- Strategy enabled eventual tax-free liquidity while avoiding capital gains and depreciation recapture
3. Capital Allocation
- Paid tax on $4M to retain liquidity (~$2M tax bill)
- Invested the remaining $4M of capital gains into two Qualified Opportunity Zone Funds
4. Opportunity Zone Benefits
- Will owe tax on initial $2M gain in 2027
- But all appreciation and income from OZ fund over 10+ years is expected to be 100% tax-free
- Additional depreciation recapture is expected to be completely excluded
- Assets placed inside an irrevocable grantor trust for enhanced estate planning flexibility