March 14, 2025
By Al DiNicola, AIF®
1031 Tax Deferred Exchange Specialist & DST Advisor/Specialist
NAMCOA® – Naples Asset Management Company®, LLC
Securities offered through MSC-BD, LLC, Member of FINRA/SIPC
In the world of real estate investment, leveraging the benefits of a §1031 exchange can provide investors with a powerful tool to defer taxes and reinvest in properties. One unique opportunity within this strategy involves the use of ground lease interests. While ground leases are typically considered long-term rental agreements, they can also play a significant role in tax-deferred exchanges under specific conditions. But how exactly do ground leases fit into the framework of a §1031 exchange, and what are the benefits, challenges, and considerations investors should be aware of when using this strategy?
What is a Ground Lease?
A ground lease is a long-term lease arrangement where the tenant holds exclusive rights to the land for a specified period, typically 30 years or more. In these leases, the tenant is responsible for developing and maintaining the property, but the ownership of the land remains with the landlord. Ground leases are often used in commercial real estate, allowing tenants to build and operate properties without the upfront costs associated with owning the land.
Can a Ground Lease Be Used in a §1031 Exchange?
Yes, a ground lease can qualify for a §1031 exchange under the right conditions. The Internal Revenue Service (IRS) treats long-term leasehold interests (those lasting at least 30 years) as similar to fee simple ownership, which makes them eligible for §1031 exchange tax deferral. For investors looking to defer capital gains taxes on the sale of a relinquished property, the leasehold interest in a ground lease presents an effective and flexible option.
How Does a Ground Lease §1031 Exchange Work?
In a typical §1031 exchange, an investor sells a property and reinvests the proceeds into another like-kind property, thus deferring capital gains taxes. A ground lease §1031 exchange follows a similar process but involves acquiring a long-term leasehold interest in a property along with the right to develop or improve the land.
In this case, an investor sells a property and uses the proceeds to acquire a leasehold interest in a ground lease. The investor can then develop or improve the land according to their specifications, allowing for significant customization of the property. This type of exchange is particularly advantageous for investors seeking strategic locations for development or those who wish to avoid the high costs of purchasing land outright.
Benefits of a Ground Lease §1031 Exchange
A ground lease §1031 exchange offers several compelling advantages for real estate investors:
Tax Deferral: As with traditional §1031 exchanges, the most significant benefit is the ability to defer capital gains taxes on the sale of the relinquished property. This allows investors to preserve more capital for reinvestment and grow their portfolios without the immediate tax burden.
Cost Efficiency: Ground leases can often be more affordable than purchasing land, allowing investors to focus their capital on property development rather than land acquisition. This strategy allows for greater financial flexibility and efficiency.
Flexibility in Development: A ground lease provides the flexibility to develop or enhance the property. Investors can create customized improvements, which are particularly useful for those seeking to tailor properties to specific market needs or operational goals.
Prime Location Opportunities: Ground leases often involve securing prime real estate locations that may be unavailable for direct purchase. Investors can gain access to valuable properties in key areas without the substantial upfront costs associated with land acquisition.
Risk Mitigation: Since ground leases are long-term contracts, they offer stability for investors who benefit from fixed lease terms and reliable landowners. This can reduce the uncertainty and risk associated with shorter-term investments.
Practical Considerations and Challenges
While ground lease §1031 exchanges present significant opportunities, they also come with specific considerations that investors must navigate.
Eligibility and Lease Term Requirements: The IRS requires the lease term to be at least 30 years for the exchange to qualify. If the lease term is shorter than this, it will not be considered “like-kind” and will not qualify for tax deferral.
Improvement Requirements: In some cases, investors may choose to improve or develop the property as part of the exchange. The IRS requires that the improvements meet or exceed the value of the relinquished property to qualify for tax deferral benefits. These improvements must also be completed within 180 days of the sale of the relinquished property, adding a layer of complexity to the process.
Delaware Statutory Trust (DST) offerings. There have been and potentially, may continue to be a select number of offerings of structures built on a ground lease. These ground leases are very long in the number of years. One of the potential benefits, maybe the depreciation schedules on the asset may be on the building only. In addition, there may also be accelerated depreciation schedules and cost segregation providing additional pass-through benefits to the investors.
Involvement of a Qualified Intermediary (QI): As with any §1031 exchange, the use of a Qualified Intermediary (QI) is required to facilitate the transaction. The QI helps ensure that the taxpayer does not have direct control over the proceeds of the relinquished property sale, which is crucial for maintaining the tax-deferred status of the exchange.
Legal and Documentation Requirements: The IRS requires detailed documentation of the intended improvements and their legal description, as well as strict timelines. It is essential to have clear planning and the necessary legal and financial resources to ensure the exchange is executed correctly.
State-Specific Regulations: State laws may vary on what constitutes real property, so it’s crucial to be aware of the specific regulations in the state where the property is located. Working with an experienced legal team can help mitigate potential risks associated with state-specific rules.
Key Steps in a Ground Lease §1031 Exchange
Sale of the Relinquished Property: The process starts with the sale of the relinquished property. The proceeds are then transferred to a Qualified Intermediary.
Identification of the Replacement Property: Within 45 days of the sale, the investor must identify the replacement property (in this case, a leasehold interest in a ground lease) and any intended improvements.
Involvement of the Accommodation Titleholder (AT): During the construction period, a special purpose entity (SPE) or Accommodation Titleholder holds the leasehold interest while the investor manages the development process.
Completion of Improvements: The investor must ensure that the improvements are completed within the IRS’s 180-day window. If any issues arise during construction, contingency plans should be in place to avoid jeopardizing the exchange.
Transfer of Leasehold Interest: Upon completion, the leasehold interest, along with the improvements, is transferred to the investor, finalizing the exchange.
NAMCOA® is a SEC registered investment advisory firm that provides comprehensive portfolio management, financial planning, and fiduciary decision-making services on behalf of retirement plan sponsors. Our Difference is summarized by our fiduciary approach which enables us to better meet portfolio and retirement plan objectives, resulting in stronger risk adjusted returns for investors and peace of mind for Clients. We also focus on alternative real estate investment. Many real estate investors are seeking tax deferred solutions utilizing §1031 exchanges or Opportunity Zones.
DSTs are not for all investors. The acquisition of a DST is for accredited investors only. Contact your investment adviser for additional details on how a DST may be a solution to your §1031 Exchange and suited for your investment future. For more information on how to properly set up an IRC §1031 Tax Deferred Exchange or if you are an accredited investor and would like additional information on a DST contact Al DiNicola at 239-691-8098 or email adinicola@namcoa.com.
This is not an offer to purchase or solicitation to purchase any security, as such be made only through an offering memorandum or prospectus. Investing in securities, real estate, or any investment, whether public or private, involves risk, including but not limited to the potential of losing some or all of your investment dollars when you invest in securities. You should review any planned financial transactions that may have tax or legal implications with your personal tax or legal advisor. NAMCOA, LLC is a Registered Investment Advisor, regulated by SEC (Securities and Exchange Commission). Our corporate office is located at 999 Vanderbilt Beach Road, Suite 200, Naples Florida 34108. Securities Offered through MSC-BD, LLC, Member of FINRA/SIPC. 5 Centerpointe Drive, Ste. 400 Lake Oswego, OR, 97035. MSC-BD, LLC and NAMCOA are independently owned and are not affiliated.
Thank you.