We Decide How an Investment
Ends Before It Begins.
Most real estate investors buy first and worry about selling later. We work the other way around. Every property we acquire or build is designed from the outset to move into a debt-free trust that investors can buy into — and, eventually, into a larger fund that holds many similar properties. This page explains how that works, step by step, in plain English.
Each Business Begins Differently. From the Trust Onward, They're Identical.
Our three businesses acquire property in genuinely different ways, and it's worth being clear about how. The table below sets out those differences. What it also shows is that, once each property reaches the trust stage, the process is the same in every case.
| Comparison | Hospitality | Active Adult | Medical & Surgical |
|---|---|---|---|
| How we get the property | We acquire the hotel from its owner through the trust sale process | We build a new community from the ground up with a homebuilder partner | We buy an existing medical building, often from the physicians who practice there |
| Who we deal with | The hotel's owner, who may continue to manage it | A builder partner | A seller, often a physician group |
| When it's ready for a trust | Once the structure is agreed and the hotel qualifies | Once about 95% of the homes are rented | Once it's bought and leased |
| How long that takes | A matter of months | Roughly three years | A matter of months |
| What happens to any debt | Paid off before the hotel enters the trust | The construction loan is paid off in full | Paid off before the building enters the trust |
| Who runs the property | Often the owner's own hotel company | RREI leases the whole community and manages it | Usually the tenant itself, under a long lease |
One Architecture, Run Three Times in Parallel.
From the trust onward, everything works the same way in all three businesses: the same kind of investor share, the same pool of buyers, and the same optional move into a fund — always into that business's own fund.
-
HospitalityFrom owner via DST sale · ~6 monthsLodging DSTInterests sold to 1031 investorsHospitality REITSector-focused · unlisted
-
Active Adult BTRDeveloped by JV · ~36 monthsActive Adult DSTInterests sold to 1031 investorsActive Adult REITSector-focused · unlisted
-
Medical & SurgicalAcquired · ~6 monthsMedical DSTInterests sold to 1031 investorsMedical REITSector-focused · unlisted
Same trust mechanics, same exchange market, same elective 721 — separate vehicles in every vertical. The lanes never merge.
For overview only; not tax advice. Section 721 treatment is elective, one-way and subject to applicable guidance.
DISCLOSURE
This is a general description of how our structure works, not tax or legal advice. DST interests are securities. Whether any tax benefit applies depends on your own situation, and the IRS sets strict rules for 1031 exchanges and DSTs (including Revenue Ruling 2004-86). Exchanging into a fund under Section 721 is optional, cannot be reversed, and is only available where the tax rules allow it. Please speak with your own tax and legal advisors.
For selected hotels, a direct contribution option may also be available; the Hospitality page explains how to discuss it with us.
A Delaware Statutory Trust, Explained Simply.
A Delaware Statutory Trust — usually shortened to "DST" — is a legal entity set up under Delaware law to hold title to a property. Instead of one owner, a DST can have many investors, each of whom owns a fractional share of the trust. Those shares are called beneficial interests.
What makes a DST so useful is how the IRS treats it. Under a 2004 ruling (Revenue Ruling 2004-86), a properly structured DST is not taxed as a separate business. Instead, each investor is treated as though they own their slice of the real estate directly. That matters because it means a DST share can qualify as replacement property in a 1031 exchange — the rule that lets someone who sells an investment property defer the tax on their gain, provided they reinvest the proceeds in other real estate. Rental income and depreciation pass straight through to each investor in proportion to their share.
There is a catch. To keep that favorable treatment, a DST must stay completely passive. The trustee holds the title, but it cannot actively run a business. So when a property does need hands-on management — a hotel with guests arriving every day, or a community whose residents sign new leases every year — a separate company, called the master tenant, leases the entire property from the trust and runs it. The trust simply collects rent and passes it on to investors.
Selling a Property in Shares, Not All at Once.
Rather than finding one buyer willing to pay the right price on one particular day, the property is divided into shares and sold to many investors over several months.
6–12 months
Target share-sales period
-
01
Moving the Property into the Trust
When the owner places the property into the trust, the transfer is structured so that it does not, by itself, trigger any tax. The owner's existing holding period carries over.
-
02
Selling Shares, Not the Building
Shares in the trust are offered to investors at a price based on an independent appraisal of the property. The goal is to sell them over roughly six to twelve months.
-
03
Tax is Spread Across the Sale
The original owner pays tax on their gain only as each share is sold — spread across the sales period rather than all falling due on a single closing date.
-
04
The Trust Stays Hands-off
Where the property needs day-to-day management, an operating company runs it under a master lease, so the trust itself never has to.
-
05
Investors Decide the Ending
When the trust reaches the end of its term, each investor chooses for themselves: take cash, reinvest through their own 1031 exchange, or exchange their share for units in a fund under Section 721.
Seven Rules Every DST Must Follow — and How We Plan for Each.
The IRS rules that give DSTs their tax advantages also make them rigid. A DST can't adapt once it's set up, so everything has to be planned properly at the start. Here's how we handle each rule.
Raise more money from investors after it closes
We fund all the reserves the property will need for its entire planned life at the very beginning, so we never need to ask investors for more.
Borrow money or refinance
We pay off any debt before the property enters the trust. Our hotel trusts never carry debt at all.
Reinvest the money from a sale
Sale proceeds must be paid out to investors, which is exactly why we plan the exit in advance.
Hold on to surplus cash
We set the reserves generously at the start, so paying out income never leaves the property short of working capital.
Carry out major renovations
We only place new or recently completed properties into trusts, and pay for any known work before the trust closes.
Sign new leases or change existing ones
A master lease — or a long lease that outlasts the trust — sits between the trust and the day-to-day business.
Let its trustee actively manage the property
The trustee only holds title. Every operating decision is made by the master tenant or operator.
Put all of that together and you can see why a DST has to have an end date. A structure that can't raise money, borrow, reinvest or sign new leases can hold a finished, stable property and pay out its income very well — but it can't respond to change. So every DST is built with a defined term that ends in either a sale or the optional move into a fund. Across the market, DSTs typically run for five to ten years. We set each program's target term when the trust is formed and state it in the offering documents.
A Large, Established Market of Motivated Buyers.
$8.41B
Invested in DSTs in 2025
Up 49% from $5.66 billion the year before.
55
DST sponsors
Running 92 separate programs as of January 2026.
51%
In residential property
Homes and apartments are the largest single category.
Source: Mountain Dell Consulting; First American Exchange Company. These figures describe the whole U.S. DST market as of January 2026, not RREI's own results.
+49% in 2025. Hatched bar shows the forecast range.
Source: Mountain Dell Consulting; First American Exchange Company, January 2026. Market-wide figures, not RREI results.
45 days
To identify
180 days
To complete
Most people who buy DST shares have just sold an investment property and are completing a 1031 exchange. The rules give them 45 days to identify what they'll buy next and 180 days to complete the purchase. If they miss either deadline, the entire tax they had hoped to defer — on their capital gain, on the depreciation they claimed over the years, and the additional 3.8% tax on investment income — becomes due. For that buyer, a finished, fully leased, debt-free property that has already been inspected and appraised, and that can close within days, is exactly what they need. That dependable demand is what our exit relies on.
Moving Into a Fund That Owns Many Similar Properties.
At the end of a trust's term, investors can choose to exchange their shares for units in RREI's private REIT for that type of property. It's a significant decision, so here is an honest look at what it offers and what it costs.
A REIT, or real estate investment trust, is a company that owns a portfolio of income-producing properties. Our REITs are private, which means their shares are not traded on a stock exchange. The exchange works under Section 721 of the tax code: investors contribute their trust shares to the REIT's operating partnership in return for “OP units,” which carry the same economic value as REIT shares. Where the tax rules allow it, that contribution is designed not to trigger tax at the time it happens.
| What the move can offer | What it costs you |
|---|---|
| Income from many properties across many markets, rather than a single building | It can't be undone. Once you hold OP units, you can never use them in another 1031 exchange |
| No tax due at the moment you make the exchange, where the tax rules allow it | You still carry the risk of that one type of property — a hotel fund is still exposed to the hotel industry |
| The ability to cash out a little at a time, managing your tax bill year by year | You still carry the risk of that one type of property — a hotel fund is still exposed to the hotel industry The fund is private and unlisted. Withdrawals are limited, may involve a waiting line, and can be paused |
| No forced sale date — you can hold your units for as long as you like | Your units are valued by independent appraisal, not by a live market price |
| If units are held until death, heirs may receive them with a stepped-up tax basis | Converting OP units into REIT shares is generally a taxable event |
Put simply, each of our funds is a private REIT focused on a single type of property, with limited ways to withdraw your money. That is a meaningful step up from owning one building you can't easily sell — but it is not the same as owning shares you can sell on the stock market, and we won't describe it as if it were.
How the Full Path Can Work Across a Lifetime — and Beyond.
Taken together, the steps on this page form a path that can run for decades. It can begin in either of two ways. An investor may sell an appreciated property and reinvest through a 1031 exchange in one of our debt-free trusts, deferring their tax. Or an accredited investor or family office may reinvest returns earned in our other programs into a trust; those returns are taxed when earned, but gains from that point forward can follow the same steps. When the trust ends, they can exchange their share for REIT units under Section 721, trading a single building for a portfolio without triggering tax at that point. From there, they can redeem units gradually, choosing how much gain to recognize each year, or simply hold them. Under current federal tax law, units still held at death generally pass to heirs with a basis stepped up to their value at that time — so the gain deferred over the investor's lifetime may never be taxed.
For a family that holds appreciated real estate, that can mean moving from a concentrated, management-heavy property to a passive, diversified holding that is simpler to divide among heirs — while keeping more of its value invested along the way.
Three honest limits apply. The path only works for investments that qualify for deferral in the first place. Each step has its own costs and restrictions — trust shares can't be sold early, the Section 721 exchange can't be undone, and REIT withdrawals are limited. And the step-up in basis is a feature of current tax law that Congress can change. We encourage every investor to plan this path with their own tax and estate-planning advisors.
defers the gain
then reinvested
debt-free RREI DST
into sector REIT
gradually
basis (current law)
Returns are taxed when earned; reinvesting, where a program offers it, starts the path from that point. Hotel sales through a trust are not deferred.
Illustrative design only; not a promised outcome or tax advice. Deferral requires meeting IRS rules; step-up depends on current law, which can change. Loss of principal is possible
DISCLOSURE
This describes how our structure is designed, not a promised outcome, and is not tax, legal or estate-planning advice. Tax deferral depends on meeting strict IRS requirements; the Section 721 exchange is optional and cannot be reversed; and REIT redemptions are limited and can be paused. Step-up in basis depends on current federal tax law, which can change, and on each investor’s estate circumstances. You could lose money. Please consult your own tax, legal and estate-planning advisors.
Important disclosure
General information only; not tax, legal or estate-planning advice. Outcomes depend on individual circumstances and on tax law in effect at the time.
If Each Business Has Its Own Funds, What's the Advantage of One Firm?
It's a fair question. Because we keep the vehicles separate, investing with RREI doesn't mix your money across healthcare, housing and hotels. The benefit of working with one firm is different, and it's real:
One Set of Standards
We apply the same discipline to every deal — how we test demand, how much we're willing to borrow, how we size reserves — so if you've examined how we work in one business, you understand how we work in all three.
A Structure That's Already Built
The trust setup, the master-lease design and the path into a fund are designed once and then reused. Each new deal benefits from the last, instead of starting from scratch.
The Right Door for Your Situation
A hotel owner, an investor looking for exposure to housing, and a group of physicians who own their building can each come in through the vehicle that fits them.
One Relationship
One set of principals, one reporting standard and one point of contact, however many of our businesses you invest in.
What it doesn't do is spread your risk across different kinds of property inside any single investment. We'll never suggest that it does.
Key Terms, in Plain English.
- Accredited investor
- An investor who meets SEC income, net-worth or professional-license tests. Only accredited investors can invest in our offerings.
- 1031 exchange
- A tax rule that lets someone sell an investment property and defer tax on the gain, as long as they reinvest the proceeds in other real estate within strict deadlines.
- 45 / 180
- The 1031 deadlines: 45 days after a sale to identify replacement property, and 180 days to finish buying it.
- Delaware Statutory Trust (DST)
- A trust that holds a property and lets many investors each own a share of it. Each share is treated as direct ownership of real estate for tax purposes.
- Beneficial interest
- An investor's share in a DST.
- Master lease / master tenant
- A single lease under which one company rents the entire property from the trust and runs it, so the trust can stay passive. That company is the master tenant.
- Section 721 exchange / UPREIT
- Contributing property — or DST shares — to a REIT's operating partnership in return for OP units, designed to defer tax. An "UPREIT" is a REIT set up to accept property this way.
- OP units
- Units in a REIT's operating partnership, worth the same as REIT shares and convertible into them over time.
- REIT
- A real estate investment trust — a company that owns a portfolio of income-producing properties. Ours are private and not traded on an exchange.
- Stepped-up basis
- Under current federal tax law, property inherited at death generally takes a new tax basis equal to its value at that time, so gain that built up during the owner's lifetime is generally not taxed.
- Depreciation recapture
- Tax owed on a sale to "pay back" the depreciation deductions claimed while owning the property.
- FF&E
- Furniture, fixtures and equipment — the beds, furnishings and equipment in a hotel. Taxed differently from the building itself.
- PIP
- Property Improvement Plan — the renovation a hotel brand requires from its owners, typically every seven to ten years.
- Stabilized
- Finished and leased or operating at a steady level — for our active adult communities, about 95% occupied.
- Net lease (triple-net)
- A lease in which the tenant pays the property's operating costs — taxes, insurance and upkeep — on top of rent.
No matching terms.
Important disclosure
This page is a general explanation, not tax or legal advice. DST interests are securities, offered only to verified accredited investors through a FINRA-registered broker-dealer and only by means of a private placement memorandum. IRS Revenue Ruling 2004-86 and Section 1031 set strict requirements. The Section 721 exchange is optional, one-way and subject to applicable tax rules. Please consult your own advisors.