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DST library · Interval funds

DST vs Real Estate Interval Fund

A DST can take 1031 exchange money; interval fund shares cannot. The fund offers quarterly 5% to 25% buybacks at NAV, but only after you pay the tax on your sale.

By Breakwater Exchange · Reviewed by our 1031 advisory team · Last reviewed

The short answer

Only the DST can receive 1031 exchange proceeds. Under Reg. section 1.1031(a)-3 stock and other securities are never real property, so interval fund shares are bought with after-tax cash, while a DST interest is treated as an undivided interest in the trust's real estate. In return the fund gives you something a DST never does: an SEC rule requires it to offer to buy back 5% to 25% of its shares at net asset value every three, six or twelve months. Use the DST for exchange dollars and treat the interval fund as a home, if any, for money that has already been taxed.

At a glance

Takes exchange proceedsDST yes; interval fund no, because fund shares are stock rather than real property
Repurchase windowInterval fund must offer to buy back 5% to 25% of shares every 3, 6 or 12 months
What a filed fund expectsOne 2025 filing says it will likely offer only the 5% minimum each quarter
Oversubscribed windowShares are bought back pro rata, so you may get only part of your request
Repurchase fee capUp to 2% of proceeds under SEC Rule 23c-3
DST exitUsually only when the manager sells the property; no redemption right
Fee shapeDST: upfront commissions plus property-level fees; fund: an annual expense ratio on net assets

Only the DST keeps the exchange alive, because interval fund shares are securities

Section 1031 defers gain only when real property is exchanged for real property. The 2020 regulations, at Reg. section 1.1031(a)-3(a)(5), list the assets that are never real property whatever state law says: stock, bonds and notes, other securities, partnership interests, certificates of trust or beneficial interests, and choses in action. An interval fund is a registered closed-end investment company, and a filed real estate interval fund registration statement says that fund intends to be taxed as a real estate investment trust. Its shares sit squarely on the excluded list.

A DST interest is different because of Rev. Rul. 2004-86. When the trustee's powers stay inside the ruling's limits, the trust is an investment trust, each investor is a grantor, and each investor is treated as owning an undivided fractional interest in the real estate itself. That is why a qualified intermediary can wire your exchange funds to a DST sponsor and to no fund.

Hypothetical: you sell a rental for a net $1,000,000 and the federal and state tax on the gain would be $150,000. Through an exchange, the full $1,000,000 goes into DSTs, less the offering load. Into an interval fund, at most $850,000 goes in, because the tax is paid first. Run your own numbers with your CPA; the comparison turns on your actual gain, recapture and state.

The interval fund's liquidity is a rule-based window, and the DST's is mostly the sale date

SEC Rule 23c-3 sets the mechanics. The fund adopts a fundamental policy to make repurchase offers at intervals of three, six or twelve months for between 5% and 25% of its shares. It must notify holders 21 to 42 days before the request deadline, price the repurchase at net asset value no later than 14 days after the deadline, and pay within seven days of pricing. It may deduct a repurchase fee of up to 2% of proceeds. If holders ask for more than the offer amount plus 2% of shares outstanding, the fund repurchases pro rata.

The filed registration statement is blunt about what that means in practice: the fund will likely offer to repurchase only the 5% minimum, an investor may not be able to sell when or in the amount desired, and shareholders should not expect a secondary market. A board can also suspend or postpone an offer, but only by a vote that includes a majority of independent directors and only in the circumstances the rule lists, such as an emergency or a closed market.

A DST has no window at all. In a filed form of DST trust agreement, investors waive any right to partition the property or demand an in-kind distribution, a transfer to a buyer you find is subject to the sponsor's right of first refusal, and the manager decides when the property sells while using commercially reasonable efforts not to sell in the first two years. The realistic exits are covered at DST illiquidity and exits.

Fees arrive at different times: the DST charges up front, the fund charges every year

DST costs are concentrated at purchase. Across 76 DST Form D filings made from April through September 2026 that reported a sales commission estimate, the estimate ran from 2.2% to 12.1% of the offering amount, with a median near 6%; you can check any trust's figures through EDGAR full-text search. Ongoing charges then sit inside the trust, such as the annual manager fee of 1.0% of gross rents in the filed trust agreement above, before cash is distributed.

The interval fund in the filed registration statement charges no sales load and shows a management fee of 0.85% of average daily net assets and estimated total annual operating expenses of 1.36%, based on $700,000,000 of net assets. The filing warns that if the fund raises much less, expenses as a percentage of net assets would be significantly higher. Other interval funds carry sales loads, so read the fee table of the one you are offered.

Neither structure promises income. The fund's filing says there is no assurance distributions will be maintained and that distributions may be funded from offering proceeds or borrowings and may be a return of capital. A DST distributes available cash after fees and reserves, and that cash depends on the tenant or master tenant paying rent; the full fee stack is at DST fees and loads.

A fund can keep buying and selling buildings; a DST is a fixed basket you report as your own real estate

Rev. Rul. 2004-86 forbids the DST trustee to acquire new property, reinvest sale proceeds, take new capital or refinance, so a trust owns on its last day what it owned on its first. An interval fund's adviser can raise money continuously, buy and sell assets and change the mix. That is real diversification inside one investment, which a DST can only approximate by splitting your money across several trusts, as described at DST diversification levels.

Reporting follows the legal form. As a DST grantor you report your share of rent, expenses and depreciation as if you owned the building. Fund shareholders receive dividends from a REIT, and when they sell shares back they sell stock, which no later exchange can defer. The broader comparison with listed and non-traded REIT shares is at DST vs REIT vs private syndication.

Exchange money belongs in a DST or direct property; taxed cash is where a fund can fit

If your goal is to defer the gain on a sale, the interval fund is not an option, and the real choice is between DSTs and direct property, compared at DST vs direct NNN property. If you are deciding whether to exchange at all, the arithmetic is at DST vs paying the capital gains tax.

The fund becomes relevant for dollars that are already taxed: cash you chose to take out as boot, savings, or proceeds from a sale you decided not to exchange. Even then, a quarterly 5% window is limited liquidity, not a deposit account. A DST bought with cash is also possible, with trade-offs covered at DSTs without a 1031.

Related questions

Can I put leftover cash from my exchange into an interval fund?

Yes, but by then it is boot and taxable in the year of the sale, so the fund is simply a cash investment made with money that has already left the exchange.

Can an interval fund stop its repurchase offers?

Only in limited cases. Rule 23c-3 allows suspension or postponement by a board vote that includes a majority of independent directors, and only for listed reasons such as loss of tax status, a closed market or an emergency.

Does a DST ever offer to buy back interests?

Not under the filed trust agreements we reviewed. The sponsor typically holds a right of first refusal if you find a buyer, and some sponsor-affiliated trusts give the sponsor an option to acquire interests for operating partnership units, which ends your exchange chain; see 721 UPREIT from a DST.

Is an interval fund less risky because it can sell shares back?

Not necessarily. The repurchase price is net asset value on the pricing date, which can fall between your request and payment, and an oversubscribed window fills only part of your request. Both structures hold illiquid real estate and can lose value.

Which costs more over ten years?

It depends on the specific load, fee basis and hold, so compare dollars, not percentages. Put the DST's upfront commission and annual trust fees next to the fund's expense ratio and any repurchase fee, and remember the fund dollars start smaller because tax was paid first.

Sources

Checked against these publications on September 30, 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.

  1. Treas. Reg. section 1.1031(a)-3, definition of real property
  2. Rev. Rul. 2004-86 (IRS)
  3. 17 CFR 270.23c-3, repurchase offers by closed-end companies
  4. Form N-2/A, October 2025, of a real estate interval fund (SEC EDGAR)
  5. Form of DST trust agreement, exhibit 10.21 to a non-traded REIT Form 10-K (2020), SEC EDGAR
  6. SEC EDGAR full-text search (DST Form D filings, April to September 2026)

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