The DST-to-721 strategy — reaching REIT ownership on a tax-deferred basis from direct property via a DST — unfolds over time in distinct phases. Understanding the full timeline, from your initial property sale through eventually holding and potentially converting REIT OP units, helps you set realistic expectations and plan. The process includes the deadline-bound 1031 sale and DST exchange (45/180 days), a period of holding the DST, a 721 exit if and when the DST is acquired by a REIT, a lock-up period on the OP units, and eventually the conversion or continued holding of the units. Importantly, the 721 exit is at the REIT sponsor's option and is not guaranteed — if it never occurs, the DST simply proceeds to an ordinary full-cycle sale. This guide walks through the timeline chronologically, phase by phase, so you understand what happens when.
The full timeline overview
The DST-to-721 process spans several phases from your property sale to holding REIT OP units. In overview: you sell your property and do a 1031 exchange into a DST (Phase 1, deadline-bound), hold the DST (Phase 2), the DST may be acquired by a REIT in a 721 exit (Phase 3), you hold the OP units through a lock-up (Phase 4), and eventually you convert or continue holding the units (Phase 5). The path runs from the 1031 sale through a potential 721 exit into ongoing OP unit ownership.
The total timeline varies. The deadline-bound 1031 step is fast — within 180 days — but the DST holding period and the timing of any 721 exit are open-ended, occurring on the DST/REIT's schedule if the sponsor elects to proceed, potentially years later or not at all. The OP unit holding that follows is indefinite. In practice the process can span years, with only the 1031 step time-bound.
Because the 721 exit depends on the sponsor's decision, it may never happen. If it does not, the DST runs its normal course to a full-cycle sale rather than an UPREIT transition, which is generally a taxable event unless you complete another qualifying exchange. Knowing the phases and their timing up front helps you set realistic expectations for reaching — and holding — REIT units, and frames the phase-by-phase walkthrough that follows.
Phase 1: The 1031 sale and DST exchange
Phase 1 is the deadline-bound 1031 exchange into a DST — the starting point. You sell your relinquished property, and within the 1031 deadlines — 45 days to identify the DST and any backups, 180 days to close — you exchange into a DST structured for a possible 721 exit. The clock is tight, but a DST's relative speed and closing predictability make the deadlines manageable.
Phase 1 involves engaging a qualified intermediary before selling, selling the relinquished property, identifying the DST within 45 days, and closing within 180 days. The gain is deferred under Section 1031, and you transition from your property into a passive DST interest. The DST should be one structured for a 721/UPREIT exit so that a later transition is possible.
Phase 1 is the only deadline-bound step. Once you are in the DST, the phases that follow — holding and any 721 exit — are not deadline-pressured, so the time-critical work is front-loaded into these first 180 days.
Phase 1 — the 1031 sale and exchange into a DST — is the only deadline-bound phase, with the familiar 45/180-day clock; once you're in the DST, the rest of the journey isn't deadline-pressured.
Phase 2: Holding the DST
Phase 2 is holding the DST, the period between the 1031 exchange and any 721 exit. After closing in Phase 1, you hold your DST interest as a passive investor, and the gain remains deferred under Section 1031. DSTs are structured to pay distributions, but distributions are not guaranteed and may be reduced or suspended.
Phase 2 is open-ended. It lasts until a 721 exit occurs, which depends on the DST/REIT structure and the sponsor's plans — potentially a few years out, on a less defined timeline, or not at all. This real holding period also matters for the step-transaction analysis, since a genuine DST investment with real duration supports the structure.
In short, Phase 2 is the open-ended middle stretch: you hold a passive DST interest with the gain deferred while waiting to see whether and when a 721 exit materializes. Its length depends on the sponsor's timing, so set your expectations for reaching the REIT accordingly.
Phase 3: The 721 exit
Phase 3 is the 721 exit, if it happens — when a REIT acquires the DST and you transition into OP units. The exit is at the REIT sponsor's option and may never occur. If a REIT does acquire the DST's property, your DST interest is converted into OP units in the REIT's operating partnership under Section 721, deferring the gain again. If no REIT acquires the DST, there is no Phase 3: the DST instead proceeds to an ordinary full-cycle sale, which is a taxable event unless you complete another qualifying exchange.
After a 721 exit, you hold OP units in the REIT — a stake in its broader portfolio, with the associated diversification and a potential path to liquidity. You have moved from a single DST into the REIT. This transition is the pivotal step of the strategy.
The timing of a 721 exit is not fixed. It depends on the DST/REIT structure and the sponsor's decision to acquire the DST, so it runs on the structure's schedule rather than a statutory deadline — and, again, it is not guaranteed. Reviewing the expected exit terms in the DST's offering documents helps you anticipate when, or whether, you would reach the REIT.
Phase 4: Holding OP units (lock-up)
Phase 4 is holding the OP units, beginning with a lock-up period. After a 721 exit, you hold OP units in the REIT, and there is typically a lock-up — often around a year — before you can convert them to REIT shares. During the lock-up you hold the units and the gain stays deferred, but conversion is not yet available. Any distributions during this time are, again, not guaranteed.
After the lock-up, you can continue holding the OP units indefinitely if you choose not to convert, with the deferral continuing and potentially carrying toward a step-up in basis at death. Phase 4 is therefore the ongoing OP unit holding period, starting with the lock-up and lasting as long as you hold the units.
In short, Phase 4 is where you settle into REIT ownership as an OP unit holder: the lock-up delays conversion at first, after which you either keep holding or move to convert in Phase 5.
- Phase 1: the 1031 sale and DST exchange (45/180-day deadlines) — the only deadline-bound phase.
- Phase 2: holding the DST (passive income, deferral) for the open-ended period until the 721 exit.
- Phase 3: the 721 exit (the REIT acquiring the DST, converting your interest into OP units) — the pivotal step into the REIT.
- Phase 4: holding OP units (starting with a lock-up); Phase 5: converting for liquidity (taxable) or holding toward the step-up.
Phase 5: Conversion and liquidity
Phase 5 is conversion and liquidity, the final stage where you access value or keep holding. After the lock-up, you can convert your OP units to REIT shares, and converting triggers the deferred gain as a taxable event. Whether conversion actually produces liquidity depends on the REIT: shares of a publicly traded REIT can generally be sold, but shares of a non-traded REIT may themselves be illiquid and subject to repurchase-program limits.
You can convert gradually to manage taxes and spread liquidity over time, convert more as needed, or keep holding the units to continue the deferral and earn income — potentially toward a step-up in basis at death. Phase 5 is open-ended and flexible: convert for liquidity, which is taxable, or hold for continued deferral, as your needs dictate.
Phase 5 is really the ongoing management of your OP units — converting for liquidity or holding to preserve deferral. Rather than ending at a fixed point, the timeline settles into ongoing OP unit ownership with the conversion option available on your schedule.
How Baker 1031 helps through the timeline
Baker 1031 Investments helps investors navigate the full DST-to-721 timeline — the deadline-bound 1031 exchange into a DST (Phase 1), the DST holding (Phase 2), a potential 721 exit (Phase 3), the OP unit lock-up and holding (Phase 4), and conversion and liquidity (Phase 5). We help you understand and manage each phase with realistic expectations for the timing.
DST interests, REIT units, and related securities are offered through the broker-dealer, Aurora Securities, Inc. (member FINRA/SIPC), and any recommendation follows a suitability review — the DST and 721 steps involve securities, available to suitable investors after a review. We coordinate with your qualified intermediary (Phase 1's deadlines), CPA (the tax across the timeline), and the REIT/DST sponsors. Our role is to help you navigate the DST-to-721 process from start to finish — the deadline-bound 1031, the DST holding, any 721 exit, the OP unit holding, and conversion — so you understand what happens when and manage each phase. The process can span years with distinct phases, and we help you through them so your transition from property to REIT units is well managed across the full timeline.
Frequently Asked Questions
What is the DST-to-721 timeline?
It is the path from your property sale to holding REIT OP units, in five phases: the 1031 sale and DST exchange within 45/180 days (Phase 1), holding the DST until any 721 exit (Phase 2), the 721 exit itself if the sponsor elects it (Phase 3), holding OP units through a lock-up (Phase 4), and conversion or continued holding (Phase 5). Only Phase 1 is deadline-bound; the rest run on the DST/REIT's schedule and can span years — and the 721 exit is not guaranteed to occur.
How long does the whole DST-to-721 process take?
There is no fixed total. Phase 1 is quick — within 180 days — but the DST holding and any 721 exit are open-ended, and OP unit ownership afterward is indefinite, so the timeline commonly runs for years. Ask about the expected 721 exit window for your specific DST before you invest.
Which phase has deadlines?
Only Phase 1. The 1031 into the DST runs on the 45-day identification and 180-day closing clocks; everything after that moves on the REIT's schedule and yours, with no statutory deadlines.
What happens during the DST holding phase?
You hold a passive DST interest and the gain stays deferred under Section 1031, typically receiving distributions — though distributions are not guaranteed. This continues until a 721 exit occurs, which is open-ended, and the real holding duration also supports the structure under a step-transaction analysis.
When does the 721 exit happen?
Whenever the REIT sponsor elects to acquire the DST — often a few years after the exchange, on a structure-driven schedule rather than a deadline. It is at the sponsor's option and may not happen at all, so confirm the expected exit terms in the DST's documents before investing.
What is the lock-up in the timeline?
After a 721 exit, Phase 4 begins with a lock-up — often around a year — during which you hold the OP units and defer the gain but cannot yet convert them to REIT shares. Once it ends, you can convert (Phase 5) or keep holding.
When can I get liquidity in the process?
Conversion liquidity is available only after the OP unit lock-up, which itself follows the 721 exit — so it comes late, and only if a REIT is publicly traded; non-traded REIT shares may remain illiquid. Before then, your only cash flow is distributions, which are not guaranteed, so do not rely on principal liquidity until after the lock-up.
Is the process the same for everyone?
The five phases are common to this path, but the timing is not. Phase 1 is always deadline-bound, while the DST holding and 721 exit depend on the specific offering and the OP unit phases depend on your choices — so review your DST's expected timeline rather than assuming a standard one.
Can I exit early?
Only with limits. DST interests are generally illiquid during the holding phase, and once you hold OP units, exiting means converting and selling, which triggers the deferred gain. This is designed as a longer-term commitment, so weigh the limited liquidity at each phase before you invest.
How does Baker 1031 help through the timeline?
We help you plan and manage each phase — from the deadline-bound 1031 into a DST through any 721 exit and the OP unit and conversion phases — and coordinate with your QI, CPA, and the sponsors. DST interests and REIT units are offered through Aurora Securities (member FINRA/SIPC) after a suitability review.
Can the 721 exit happen automatically, or do I have to act?
It depends on the structure. In many DST-to-721 programs the exit is built in: when the REIT elects to acquire the DST, your interest converts into OP units largely automatically under the offering's terms, without you initiating it. Specifics vary, so review the DST's documents to see how and when an exit is expected and whether any action is needed on your part.
What if I want to stay in the DST and not move to the REIT?
A DST-to-721 structure is designed to reach the REIT, so staying in the DST indefinitely may not be an option. If you prefer a DST with no planned 721 exit, a standalone DST may fit you better — so confirm before investing whether the structure contemplates an exit or allows you to remain in the DST.
Does the timeline restart the 1031 deadlines at the 721 exit?
No. The 45/180-day deadlines apply only to the initial 1031 exchange into the DST. The 721 exit is governed by Section 721, not Section 1031, so it carries no new like-kind deadlines and happens on the DST/REIT's schedule.
How should I plan around the timeline?
Move fast at the front — engage a QI early, identify within 45 days, and close within 180 — then treat the middle as open-ended and confirm the expected 721 exit window for your DST. Don't count on principal liquidity until after the lock-up, and plan for the conversion tax or for holding toward a step-up in basis.
Glossary
- DST-to-721 Timeline
- The full path from property sale to REIT OP units.
- Phase 1
- The 1031 sale and DST exchange (45/180-day deadlines).
- Phase 2
- Holding the DST until the 721 exit (open-ended).
- Phase 3
- The 721 exit into the REIT (OP units).
- Phase 4
- Holding OP units, starting with the lock-up.
- Phase 5
- Conversion and liquidity (or continued holding).
- 45/180-Day Deadlines
- The 1031 deadlines in Phase 1.
- Qualified Intermediary
- The party handling Phase 1's 1031 mechanics.
- DST Holding Period
- Phase 2's open-ended wait for the 721 exit.
- 721 Exit
- Phase 3's transition from the DST into the REIT.
- Lock-Up Period
- Phase 4's initial wait before converting units.
- Conversion
- Phase 5's exchange of units for shares (taxable).
- Continuous Deferral
- The gain deferred across the timeline's phases.
- Open-Ended Timing
- The non-deadline timing of Phases 2-5.
- Distributions
- The income earned during the hold, not guaranteed.
- Structure-Driven
- The 721 exit timing set by the DST/REIT structure.
Sources & References
- Cornell Legal Information Institute. 26 CFR § 1.1031(k)-1 — (1031 deadlines)
- Cornell Legal Information Institute. 26 U.S. Code § 721 — Nonrecognition of gain or loss on contribution
- IRS. Revenue Ruling 2004-86 (Delaware Statutory Trusts)
- U.S. Securities and Exchange Commission. Investor.gov — Real Estate Investment Trusts (REITs)
Disclosures
This article is published by Baker 1031 Investments, LLC for general educational purposes for accredited investors and is not an offer to sell or a solicitation of an offer to buy any security, nor is it tax, legal, accounting, or investment advice or a recommendation. Any securities offering is made solely through a sponsor’s private placement memorandum (PPM) following a suitability determination. Securities offered through Aurora Securities, Inc. (ASI), member FINRA / SIPC; Baker 1031 Investments is independent of ASI.
Oil & gas mineral and royalty interests and DST programs are speculative, illiquid securities sold only to verified accredited investors and involve substantial risk, including possible loss of principal, commodity-price and production-decline risk, lack of control, and the risk that an intended 1031 exchange fails to qualify for tax deferral. Whether a particular interest qualifies as like-kind real property is a fact-specific legal determination that varies by state and by the terms of the instrument. Tax results depend on your individual circumstances. Consult your own CPA and attorney before acting. Past performance does not guarantee future results.
