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1031 · Replacement property structures

The restrictions that hurt every other asset class.

The rules that make a Delaware statutory trust work for exchange purposes also make it nearly inert. It is an odd fit for most real estate, because most real estate needs managing. It is an unusually clean fit for a long bondable ground lease, which needs none.

The trustee cannot renegotiate a lease, refinance the debt or fund more than minor capital work.
Guidance on trusts used as replacement property restricts the trustee in a well-known list: no new or renegotiated leases except on tenant bankruptcy or insolvency, no refinancing, no reinvestment of proceeds, no more than minor capital expenditure, and no active management. Those constraints are what preserve the exchange treatment, and they are why most trusts operate under a master lease to a sponsor affiliate.
The fit

A bondable ground lease asks for none of it.

A ninety-nine year unsubordinated ground lease with fixed contractual escalations does not require a renegotiation, because the rent schedule is written for the whole term. It does not require refinancing, because the fee can be held unlevered. It does not require capital expenditure, because the tenant owns and maintains the improvements and the landlord's obligations are close to none.

Every other asset class pays a real cost for those restrictions. A ground lease pays none, because it was never going to do any of those things anyway.

What the holder actually owns

Land, rent, and a reversion.

A leased fee under an unsubordinated ground lease is the land, the contractual right to rent for the term, and the right to the improvements at expiry. It sits ahead of the leasehold mortgage. The tenant pays taxes, insurance, maintenance and every operating expense, and the rent is due without offset or abatement.

There is no vacancy to re-lease, no tenant improvement allowance, no roof, no parking lot and no leasing commission. What looks like a thin return is the price of an obligation with very little that can go wrong operationally.

What to check

Not all ground leases are bondable.

The word doing the work is bondable. That means rent is absolute: payable without offset, abatement, deduction or counterclaim, and it does not stop for casualty or condemnation. A lease with rent abatement on casualty is not bondable and behaves very differently in a structure that cannot renegotiate.

Check three more things. Whether rent is a fixed ascertainable sum or carries a fair market value reset, which is a problem for financeability and for anyone underwriting a fixed income stream. Whether the lease is unsubordinated. And whether the leasehold mortgagee protections are the institutional package, since the quality of the tenant's financing is the quality of your rent.

Supply

The constraint on this product is inventory.

Newly created leased fee positions do not come to market often, because most ground leases in existence were written decades ago on terms that would not pass a modern lender's review. The clean ones are usually created rather than found.

That is what we do. We buy land under commercial real estate and write the lease to an unsubordinated ninety-nine year institutional form, conforming to the published agency leasehold-mortgagee standard.

Nothing here is an offer of a security. Trust interests are securities sold through licensed broker-dealers. We are a real estate principal and this page is explanatory only. Confirm exchange mechanics with your qualified intermediary and CPA.

Questions, answered

FAQ.

What are the restrictions on a trustee holding replacement property?

In summary: no new or renegotiated leases except on tenant insolvency, no refinancing, no reinvestment of proceeds, no more than minor capital expenditure and no active management.

Why do ground leases fit those restrictions well?

Because a long bondable ground lease requires no leasing, no capital work and no refinancing. The trustee has nothing it is prohibited from doing.

What does bondable mean?

Rent is payable absolutely, without offset, abatement, deduction or counterclaim, and it does not abate for casualty or condemnation.

Is a fair market value reset a problem?

For financeability, yes. Agency leasehold guidance requires rent to be a fixed ascertainable sum and treats reappraisal-based resets as unacceptable.

Who pays taxes, insurance and maintenance?

The tenant. The landlord's obligations under an unsubordinated ground lease are minimal by design.

Why is supply limited?

Most existing ground leases were written decades ago on terms a modern lender would reject. Clean institutional-form positions generally have to be created.

Get your number

If the constraint is inventory, we create it.

We write ninety-nine year unsubordinated leases conforming to the published agency leasehold-mortgagee standard. The mechanics are checkable without a call.

Email us the property