Patriot Holdings

Roll into the fund

Keep more of what you built.

A 721 exchange lets you trade your park for fund units instead of selling for cash. When it fits, you can defer the tax, stay invested, and go passive. Here is the plain-English version.

What is a 721 exchange?

A 721 exchange, sometimes called an UPREIT, lets a property owner contribute real estate to a partnership in exchange for partnership units. Because you receive units instead of cash, the IRS generally treats it as a non-taxable event under Section 721. The gain you would owe on a straight sale is generally deferred.

For a mobile home park owner, that means two of the biggest costs of selling, capital gains tax and depreciation recapture, are pushed down the road instead of paid up front. Your equity keeps working for you.

Cash sale vs. rolling into the fund

ConsiderationStraight cash saleRoll into the fund (721)
Capital gains taxDue nowDeferred
Depreciation recaptureDue nowDeferred
Ongoing incomeEnds at salePassive, if distributed
DiversificationUp to you to rebuildBuilt into the portfolio
Management burdenGoneGone

Prefer cash or a note? Those options are always on the table. The fund is for owners who want to defer the tax and stay invested.

How the exchange works

1

You contribute your park

Instead of selling for cash, you contribute the property to our fund.

2

You receive fund units

In return you get operating partnership units, valued at your park’s agreed contribution value.

3

The tax is generally deferred

Under Section 721, a properly structured exchange is generally not a taxable event, so capital gains and depreciation recapture are deferred rather than paid now.

4

You go passive

You hold units in a diversified portfolio and go fully passive. No tenants, no repairs, no management.

A note on advice: Every owner’s tax situation is different. This page explains the concept in general terms and is not tax or legal advice. Fund units, if offered, are available only to qualified investors through a private placement, and nothing here is an offer of securities. Before you decide, we’ll put you in front of the numbers for your park and you should confirm the treatment with your own tax and legal advisors.

See if the 721 fits your park

Tell us about the community and we’ll model cash, note, and fund scenarios side by side.