The short answer
One exchange produces one Form 8824, whether you sold three rentals into one building or one rental into a building and two Delaware statutory trusts. Two situations break that rule: genuinely separate exchanges get a summary Form 8824 with a statement for each, and a multi-asset exchange with more than one exchange group skips lines 12 through 18 and attaches your own computation. The single basis figure on line 25 is then allocated across the replacements in proportion to their fair market values.
At a glance
| One exchange | One Form 8824, regardless of how many properties changed hands |
|---|---|
| More than one exchange | Summary Form 8824 plus a statement per exchange; totals on lines 23 and 25 |
| Summary form entries | Name, identifying number, "Summary" on line 1, total line 23, total line 25 |
| Multi-asset | Skip lines 12–18, attach a statement, enter lines 19–25 (Reg. §1.1031(j)-1) |
| Basis split | Proportionate to fair market value, per Reg. §1.1031(j)-1(c) |
| Lines 25a–25c | Must be proportionate to the FMVs of the property received |
| Each DST | A replacement property, described by trust name and your percentage |
| Two sale dates | Both periods run from the first transfer in the exchange |
Three rentals into two replacements is still a single form
Nothing on Form 8824 asks for a property count. Lines 1 and 2 take descriptions, which can list several addresses, and the rest of the form works on totals.
The instructions reserve the plural treatment for multiple exchanges, not multiple properties: "If you made more than one like-kind exchange, you can file a summary on one Form 8824 and attach your own statement showing all the information requested on Form 8824 for each exchange."
On that summary form you enter only your name and identifying number, the word "Summary" on line 1, the total recognized gain from all exchanges on line 23 and the total basis of all like-kind property received on line 25. Everything else lives on the attached statements.
The practical test is how many exchange agreements your intermediary opened. Two agreements, two sets of 45-day notices and two pools of funds are two exchanges; one agreement covering several closings is one, however many deeds were signed.
When you skip lines 12 through 18 and attach your own computation instead
The multi-asset rule is narrower than it sounds. A multi-asset exchange "involves the transfer and receipt of more than one group of like-kind properties," and the transfer or receipt of several properties within one like-kind group counts too.
The reporting instruction applies where you transferred and received more than one group of like-kind properties, or cash or other non-like-kind property. In that case you leave lines 12 through 18 blank, attach a statement showing how you figured the realized and recognized gain, and enter the right amounts on lines 19 through 25.
For real estate exchanges after 2017 this rarely bites, because only real property qualifies and it forms a single group. It resurfaces when non-like-kind property changes hands on both sides, and the computation then follows Regulations section 1.1031(j)-1.
Selling three properties: one exchange or three?
The answer is set by the paperwork, not by the number of closings. Properties sold under one exchange agreement, with the proceeds pooled by one intermediary and applied to a common set of replacements, are one exchange on one form.
Both deadlines then run from the earliest of the transfers, so the third seller effectively has fewer than 45 days to identify. Whether one property into several, or several into one, is allowed at all is the prior question.
Sales that straddle two tax years cannot share a form, because each Form 8824 belongs to the return for the year of its own transfer. A November and a February closing are two returns whatever the exchange agreement says.
Each trust interest is a replacement property, not a security position
Describe a Delaware statutory trust on line 2 the way you would describe a building: the trust's name, the underlying property or portfolio, and your percentage interest. You are treated as owning an undivided interest in the real estate itself, which is why the interest qualifies as like-kind at all.
Dollar amounts come from the closing statement and the sponsor's confirmation: your equity, your share of any nonrecourse debt at the trust level, and the closing date that goes toward line 6. A trust with no debt contributes nothing to the debt side of line 15 or line 18.
Two trusts plus a direct purchase are three replacements on one form, and the closing date on line 6 should be the last of them, since the exchange is not complete until you have received everything. Whether the trust's own loan counts as replacement debt decides whether your line 15 shows mortgage boot.
Three rentals into a retail building and a trust: $2,400,000 across one form
Hypothetical, round figures, closing costs already netted out of the sale figures. Three rentals sold under one exchange agreement realize $2,400,000 together, carry $700,000 of combined adjusted basis and have $800,000 of mortgages paid off, leaving $1,600,000 with the intermediary.
- Replacements: a $1,300,000 retail building with a new $550,000 loan, taking $750,000 of cash, and a trust interest with $850,000 of equity plus $250,000 of allocated nonrecourse debt, a $1,100,000 value.
- Line 15: zero. The $800,000 of debt discharged is matched by $800,000 assumed, and no cash came back.
- Line 16: $2,400,000. Line 18: $700,000. Line 19: $1,700,000 realized, all deferred on line 24.
- Line 25: $700,000, allocated $379,167 to the retail building ($1,300,000 of $2,400,000) and $320,833 to the trust interest.
- Line 25a takes the §1250 share of each, with line 25b used only if either replacement delivered §1245 property.
- Variant: leave $20,000 unspent and line 15 becomes $20,000, line 23 becomes $20,000, line 24 drops to $1,680,000 and line 25 stays at $700,000.
The allocation matters more than the total, because each replacement gets its own schedule
Regulations section 1.1031(j)-1(c) requires the aggregate basis to be "allocated proportionately to each property received in the exchange group in accordance with its fair market value," and the Form 8824 instructions repeat the requirement for lines 25a through 25c.
That split is what your depreciation software needs. Each replacement is then divided again between the carried-over portion and the trade-up portion, so a two-replacement exchange produces four schedules.
Keep the allocation worksheet with the form, because the next exchange or sale of either property starts from its share and nothing else records it. Have your CPA or attorney confirm the split before the return is filed.
Related questions
Do I file a separate Form 8824 for each DST I bought?
No. Several trusts acquired in one exchange are several replacement properties on a single form, described together on line 2 and totalled through Part III.
One relinquished sale closed in December and another in January. What then?
Two returns and two forms, because each belongs to the year of its own transfer. The January sale usually cannot be part of the same exchange in any event once the earlier 45-day period has run.
My sponsor gave me a percentage interest rather than a dollar value. What do I enter?
Use the equity you funded plus your allocated share of the trust's debt as the fair market value, and put the percentage in the line 2 description. The sponsor's closing confirmation carries both figures.
If a small amount of cash comes back, which replacement's basis does it reduce?
None of them individually. Line 15 reduces the single line 25 figure before the allocation happens, so every replacement's share falls in the same proportion.
Can I put part of the proceeds into a trust and buy the rest directly?
Yes, and it is a common way to place an awkward remainder without leaving cash on the table. How to size the split between a trust and a direct purchase is the decision that comes before the form.
I sold one property and bought five. Is that a multi-asset exchange?
Under the regulation it is, because several properties sit in one like-kind group, but with real property on both sides and no other asset classes involved the ordinary lines 12 through 18 still work. The attachment rule is aimed at exchanges with more than one group or with non-like-kind property on both sides.
Sources
Checked against these publications on September 19, 2026. Rules and figures change; confirm the current version with your CPA or attorney before you act. This page is general information, not tax or legal advice.
- IRS Instructions for Form 8824 (2025), Multiple exchanges and Multi-Asset Exchanges
- 26 CFR §1.1031(j)-1, Exchanges of multiple properties (Cornell LII)
- IRS Form 8824 (2025), Part III caution on multi-asset exchanges
- IRS FAQ: reporting a like-kind exchange on your return
- 26 CFR §1.1031(d)-1, Property acquired upon a tax-free exchange
- IRS Publication 544, Multiple-Property Exchanges
