Guide — not an offering

The QI holds the cash. The DST is a different product.

This page is editorial. It is not tax, legal, or investment advice, not a sponsor pitch, and not an offer of any security or exchange service. Delaware Statutory Trust interests are typically sold as securities. A Qualified Intermediary listing on this site is a custody file.

Two jobs in one exchange

In a delayed 1031, Treasury’s Qualified Intermediary safe harbor (Treas. Reg. §1.1031(k)-1(g)(4)) is about constructive receipt. The QI is the unrelated party that documents the exchange and holds sale proceeds so you do not take the money. That is a cash-and-paper job. There is no federal QI license.

A Delaware Statutory Trust is a replacement-property structure. IRS Revenue Ruling 2004-86 is the usual cite for treating a beneficial interest in a properly limited DST that holds real property as an interest in that real property for §1031. The holdings and the trustee-power list are restated onDST as replacement property. The trust, the sponsor, the private placement memorandum, and the broker-dealer are not the QI.

Same closing calendar. Different contracts. If you mix them up, you will diligence the wrong stack.

What “DST: yes” means on a QI File row

On a firm page it means the QI published that it administers exchanges in which the replacement property is (or can be) a DST interest. It does not mean the QI underwrites the real estate, sets the rent projection, or sells you the trust units. It is not a rating of any DST sponsor.

DST interests are generally securities. They are usually available only to accredited investors through a licensed broker-dealer after a suitability review. The QI wires exchange funds when your identification and the subscription documents say to. The QI does not replace the PPM.

What to ask each side

Ask the QI (custody): How is the account titled? Whose TIN? Who can release a wire? Where is the current fidelity / E&O declaration? Is a DST closing treated like any other replacement closing on the exchange agreement?

Ask the DST side (securities / real estate): Who is the sponsor and the trustee? What does the PPM say about leverage, reserves, the trustee powers listed in Rev. Rul. 2004-86, fees, and exit? Who is the broker-dealer of record? Illiquidity and loss of capital are ordinary DST risk-factor language — read them as written. The ruling’s power list is on DST as replacement property.

What this directory will not do

We will not turn a QI custody page into a DST marketplace. Sponsor pages, if added later, will be labeled as securities-offering files and kept off the QI table. We will not invent yields, load fees, or “best DST” copy. If a QI only published a blog explaining what a DST is, that is not enough for a “DST: yes” badge — the firm has to say it does the work.

Read how to read a listing before treating any badge as diligence complete. Then open the QI file for the sources that firm actually published. Choosing the intermediary is a custody decision — start with how to choose a QI.

FAQ

Is a DST interest like-kind real property?

Rev. Rul. 2004-86 holds that, on its facts, exchanging real property for an interest in the described Delaware statutory trust can qualify under §1031 if the other requirements of §1031 are met. Additional trustee powers listed in that ruling can cause partnership classification. See DST as replacement property. The ruling is not an offering.

Does “DST: yes” on a QI File row mean the QI is the sponsor?

No. It means the QI published that it administers exchanges in which replacement can be a DST interest. The sponsor, trustee, PPM, and broker-dealer are a different stack. A QI listing here is a custody file.

Sources

Rev. Rul. 2004-86 — irs.gov/pub/irs-drop/rr-04-86.pdf. Accessed 2026-09-11.
Treas. Reg. §1.1031(k)-1(g)(4) — QI safe harbor. Accessed 2026-09-11.

Not tax, legal, or investment advice. Not an offer of any security.