TIC vs. DST Comparison

 

TIC Structure

DST Structure

IRS Reference Rev. Procedure 2002-22 Rev. Ruling 2004-86
# of Investors 35 maximum 499 maximum
Ownership Interest Direct ownership in real property as an undivided Tenant in Common Proportional ownership in the DST itself, no ownership of real property
Who Holds Real Property Deed? Individual owners each hold their own. DST – the trust itself
Major Decision Approval Yes. Unanimous approval required. None. Only have voting rights re: appointment of trustee, etc.
# of Borrowers Each investor in the TIC, up to 35 One (the DST itself)
Personal Liability Protection No – unless the investor holds ownership via an LLC Yes