The short answer
You can match your rent dollar for dollar only if you compare like with like: the rental's net cash after vacancy, repairs, reserves and debt service, divided by the equity a sale actually frees after selling costs and the loan payoff. That ratio is the distribution rate the replacement must pay. In the hypothetical fourplex below, $39,200 of true net cash on $1,016,000 of freed equity needs about 3.9%, not the 5.7% the owner's checkbook suggests. A DST pays whatever cash its trust has left after its own expenses, fees and reserves, so the rate is a projection that can fall, and it is taxed on Schedule E much like rent.
At a glance
| Income to replace | Net cash after vacancy, repairs, capital reserves and mortgage payments |
|---|---|
| Rate you need | Annual net cash flow divided by equity freed after selling costs and loan payoff |
| How a DST pays | The model trust in Rev. Rul. 2004-86 distributes all available cash less reserves |
| No new money | A DST trustee cannot accept additional contributions or renegotiate the lease or loan |
| Debt paid off at sale | Treated as money received unless matched by replacement debt or added cash |
| Depreciation after exchange | Carryover basis keeps its remaining schedule; only excess basis starts fresh |
| Accredited investor | Net worth over $1,000,000 excluding your home, or income over $200,000 single or $300,000 joint |
The income you are replacing is net cash after vacancy, repairs and reserves, which is smaller than a good year's checkbook
Most landlords measure their rental income as rent collected minus the mortgage, taxes and insurance. That figure leaves out the month a unit sat empty, the water heater, the turnover paint and the roof you are quietly saving for. A DST distribution has already absorbed those costs inside the trust, so comparing it with a checkbook number makes the DST look worse than it is.
Hypothetical: a fourplex rents for $2,000 a unit, or $96,000 a year at full occupancy. Allow 5% for vacancy and unpaid rent ($4,800), $9,000 of property tax, $5,000 of insurance, $8,000 of repairs and turnover and a $6,000 capital reserve. Net operating income is $63,200, and after a $24,000 mortgage payment the true net cash is $39,200.
The owner's checkbook in a quiet year shows about $58,000, because nothing broke and nobody moved out. That is the number most owners carry in their heads, and it overstates the income to replace by nearly half. Use three to five years of actual Schedule E figures plus a reserve for big-ticket items to get your own number; Publication 527 lists what counts as a repair expense and what must be capitalized and depreciated.
Divide that net figure by the equity a sale frees up, and the result is the distribution rate the replacement must pay
Your rental income is earned on equity you could walk away with today, not on what you paid. Equity freed is the sale price minus selling costs minus the loan payoff. In the hypothetical, a $1,400,000 sale with $84,000 of commissions and closing costs and a $300,000 payoff frees $1,016,000.
$39,200 divided by $1,016,000 is about 3.9%. Any replacement that pays at least that rate on the same $1,016,000, after its own costs, replaces the income one-for-one; the checkbook figure would have set the bar at 5.7% and ruled out choices that actually match. The same arithmetic tells you whether the property is underperforming in the first place, which Low Return on Equity Rentals works through.
Offering costs matter here. Commissions and sponsor fees taken at the start reduce how much of your money reaches the real estate, and DST fees and loads shows how to find them in the offering documents. Ask whether a projected distribution rate is computed on your full purchase price and what it assumes about vacancy and reserves. Then run your own numbers with your CPA.
- 1. Gross scheduled rent at full occupancy.
- 2. Minus vacancy and credit loss, taxes, insurance, repairs, management and a capital reserve.
- 3. Minus annual mortgage payments: this is true net cash.
- 4. Sale price minus selling costs minus loan payoff: this is equity freed.
- 5. Line 3 divided by line 4: the distribution rate you need to match.
The mortgage you pay off at closing has to be replaced too, and that decides which DSTs fit the exchange
Under Reg. section 1.1031(d)-2, a liability you are relieved of in an exchange is treated as money received. To defer all the gain, the hypothetical owner must reinvest the full $1,016,000 and also take on at least $300,000 of new debt or add $300,000 of cash, so total replacement value is at least $1,316,000.
DST interests carry a pro rata share of the trust's loan, and that share counts as replacement debt; whether DST loans count explains the arithmetic. Spreading $1,016,000 across trusts with a combined loan-to-value of about 23% or more covers the $300,000. A debt-free trust alone would leave the old mortgage as taxable boot unless you add cash.
Leverage changes the income question as well as the tax one. Trust-level debt service comes ahead of your distribution, and a loan maturity can force a sale or cut payments. Matching the old mortgage exactly with low trust leverage keeps the exchange whole without adding more debt risk than the fourplex carried.
Both income streams are taxed on Schedule E, but the depreciation that shelters them follows your old basis
A DST is a grantor trust, so you report your share of its rent, interest, expenses and depreciation as if you owned the building. Reg. section 1.671-4 requires the trustee to furnish a statement showing all items of income and deduction, and those lines go on Schedule E the same way your fourplex's do. DST tax forms and reporting walks through the statement.
The difference is depreciation. Under Reg. section 1.168(i)-6, the basis you carry over from the fourplex keeps depreciating over its remaining recovery period, using the longer period if the trust owns commercial property. Only excess basis, the part paid for with new debt or added cash, is treated as newly placed in service.
So a landlord whose fourplex is nearly fully depreciated will see most of a DST distribution taxed as ordinary income, just as most of the rent was. One whose replacement includes new debt will see fresh depreciation on that portion, which shelters part of each check. The cash may match one-for-one while the after-tax amount does not, which is why the comparison belongs on a two-column worksheet with your CPA.
A DST check is less controllable than rent, so build the replacement from several trusts and a cash cushion
In Rev. Rul. 2004-86, the IRS qualified a DST for section 1031 only because the trustee's powers are narrow: it must distribute all available cash less reserves, cannot accept new contributions, and cannot renegotiate the lease or the loan except in a tenant bankruptcy. Those limits keep the interest real property, and they also mean the trust cannot raise money to fix a shortfall the way you could with your own fourplex.
When a tenant leaves or reserves run short, distributions fall first. DST distributions: timing and reliability covers the events that cut payments. Spreading the equity across several trusts, sponsors and property types limits how much of your income one lease can take away, and our traditional DST solutions typically work with minimums between $100,000 and $250,000 per trust, which makes that split practical at this size.
Keep a cash reserve outside the exchange for the months distributions lag, paid for with savings rather than by taking boot at closing. A cash out, or zero cash flow, DST does the opposite job: its income services the debt and it pays no current distributions, so it does not belong in an income-replacement plan.
Related questions
Will a cash out DST replace my rental income?
No. Our cash out DST solutions are zero cash flow trusts that pay no current income, because operations service the debt. They are for liquidity and debt replacement, not monthly income.
Can I take some cash at closing to make up an income gap?
You can, but any cash you keep is boot and is taxed in the year of sale, starting with the depreciation layer. What is boot explains how it is measured.
Do DSTs pay monthly like rent?
The trust agreement sets the schedule. The model trust in Rev. Rul. 2004-86 distributed quarterly, and the offering documents for each trust state its own frequency.
Do I need to be an accredited investor to buy DST interests?
DST interests are securities, and offerings sold under Regulation D are commonly limited to accredited investors. 17 CFR 230.501(a) defines one as a person with net worth over $1,000,000 excluding a primary residence, or income over $200,000 single or $300,000 joint in each of the last two years.
What happens to my income if a DST cuts distributions?
You receive less, and the trustee cannot ask you for new money or renegotiate the lease to fix it. That is the reason to hold more than one trust and keep a cash reserve outside the exchange.
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.
- IRS, Rev. Rul. 2004-86, Internal Revenue Bulletin 2004-33
- Reg. section 1.1031(d)-2, treatment of assumption of liabilities
- Reg. section 1.168(i)-6, like-kind exchanges and depreciation
- Reg. section 1.671-4, grantor trust reporting
- IRS Publication 527, Residential Rental Property
- 17 CFR 230.501, Regulation D definitions
- 26 U.S.C. section 1031
