---
title: When to Consider a Zero-Coupon DST
description: A Zero-Coupon Delaware Statutory Trust (DST) is an investment that does not pay any distributions – but which can help some investors achieve important benefits that can outweigh the loss of ongoing income.
image: https://blog.fgg1031.com/hubfs/Zero%20Coupon.png
---

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## [721 UPREIT Options in DST Programs (Part 3)](https://blog.fgg1031.com/blog/721-upreit-options-in-dst-programs)

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# When to Consider a Zero-Coupon DST

By [Paul Getty](https://blog.fgg1031.com/blog/author/paul-getty)

A Zero-Coupon Delaware Statutory Trust (DST) is an investment that does not pay any distributions – but which can help some investors achieve important benefits that can outweigh the loss of ongoing income.

The underlying real estate in a Zero-Coupon DST is typically a single tenant property occupied by a larger tenant with an established credit rating such as Amazon or Verizon. Lease terms are commonly 20-years with multiple extension options and rent payments, property maintenance, and expenses are guaranteed by the tenant. These DSTs are created and managed by generally well-established sponsors who have a good financial profile. The combination of the tenant’s credit rating, lease guarantee, and sponsor profile allows lenders to provide loans ranging from 80% to 90% of the value of the property. 

All the net income of the property is used to pay down the loan over the holding period and, when the property is sold, the investor should expect (but there can be no assurance) to receive their original investment plus additional equity due to the portion of the loan that was paid off during the holding period plus any appreciation that may have occurred. Future sales proceeds from a Zero-Coupon DST can be deferred via a 1031 exchange. 

Zero-Coupon DSTs may be fit to help solve two problems. 

##### **Overcoming Challenges of Selling Assets with High Debt **

Several of our clients refinance their rental properties from time to time to obtain funds for other purposes. Money received in the form of a loan is tax-free and can generally be used for anything that the investor chooses to purchase, e.g., a new car, college tuition, property improvements, a longed-for vacation trip, etc. We have seen more refinancing activity in recent years due to clients desiring to free up trapped equity resulting from property appreciation and to take advantage of historically low interest rates. 

Investors who have [refinanced their properties](https://blog.fgg1031.com/blog/can-i-refinance-my-investment-property) may be faced with challenges in completing a 1031 exchange at time of sale. Remember that one of the rules for completing a full tax deferral is that the investor must replace the debt in the sold property with either new debt in the replacement properties or with cash from outside the exchange. 

An investor who is selling a property with a higher debt ratio e.g., 60% or greater, may find that they are unable to qualify for a new loan of equal or greater value and therefore may be stuck paying taxes on the portion of the loan that they cannot replace in their new properties. [DSTs](https://blog.fgg1031.com/blog/getting-started-with-dsts) can be a good option to consider except for the fact that most DSTs have loan to value ratios that are below 60%. 

Here is an example of where the Zero-Coupon DST may be good fit. Let’s suppose an investor sold a property with a 70% debt ratio and wishes to reinvest in DSTs with an average debt ratio of 55%. Rather than paying the taxes that would otherwise be owed due to acquiring properties with lesser debt, they could invest a portion of their funds in a Zero-Coupon DST and blend the higher 80% to 90% debt ratio in that DST with other properties having lower debt. The result could be that no (or lesser) funds are lost to taxes and the investor is able to acquire some income producing properties with lower debt ratios. 

##### **Potential Long-Term Results May Be Attractive **

We occasionally have clients who have sufficient income and are looking for a relatively secure investment that can produce an attractive capital gain over the holding period. Due to the relatively rapid pay-down of the loan in a Zero-Coupon DST plus possible appreciation of the underlying asset, the total return may be more attractive than other investments begin considered. 

##### **Consider Impact of Phantom Income  **

As the Zero-Coupon DST is paid down, there will typically be a point in time when the property’s income will exceed the loan’s interest expenses and the loan will begin to be reduced resulting in a pay-down of the principal. Pay-down of principal is considered taxable income by the IRS. Since no distributions will be paid during the holding period, the investor may need to come out-of-pocket to pay taxes owed on this so-called phantom income. 

##### **Summary**

The Zero-Coupon DST is a specialized offering that can solve problems faced by some investors. It can be especially appealing to investors selling properties with high debt ratios. Rather than losing funds to pay taxes, funds can remain in one’s estate. While the loss of income during the holding period can be a downside, investing in a Zero-Coupon DST may prove to be the lesser of two evils as compared with paying taxes.  

Investing in a Zero-Coupon DST can involve added considerations that may require inputs from your tax advisor and/or estate planning professionals plus the support of a knowledgeable DST representative who help you determine suitability for your circumstances. We always recommend that clients obtain inputs from their tax advisors before investing in DSTs.   

For more information on tax deferral strategies,1031 exchanges and 1031 replacement property options including traditional real estate and DSTs, please visit our website at [www.FGG1031.com](http://www.FGG1031.com) or contact us via phone 408 392-8822 or by email at [info@FirstGuardianGroup.com](mailto:info@FirstGuardianGroup.com) to book an appointment. 

We look forward to assisting you to make wise and informed investment decisions.

---

##### **Help Save 1031 Exchanges**

Write to your Member of Congress and Senators urging them to oppose restricting Section 1031 like-kind exchanges. As part of the American Families Plan, the Biden Administration has proposed eliminating the application of Section 1031 for gains greater than $500,000. Like-kind exchanges have been part of the U.S. tax code since 1921 and are one of the tax code’s most powerful economic tools. It is critical that we all vigorously and visibly oppose this proposal. Make your voice heard with a pre-filled letter, which you can customize to add personal anecdotes or powerful client stories to highlight the positive impact of Section 1031 like-kind exchanges. Take action today by clicking [HERE](https://p2a.co/XLBiUYT)[**.**](https://p2a.co/XLBiUYT)

---

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### [Paul Getty](https://blog.fgg1031.com/blog/author/paul-getty)

Paul M. Getty is one of the most experienced 1031 exchange specialists in the United States, with a career in real estate that spans over 35 years and more than $5 billion in commercial transactions across every major asset class. His work covers single-family rentals, apartments, retail, office, multifamily, and student and senior housing, giving him a practical understanding of how different property types perform across market cycles and how investors can move between them using tax-deferred exchange strategies. As President and CEO of FGG1031 | First Guardian Group, Paul advises investors through the full 1031 exchange process, from identifying qualifying replacement properties to structuring acquisitions through Delaware Statutory Trusts (DSTs) and wholly owned real estate. His guidance covers both the compliance requirements of a valid exchange and the investment decisions that determine long-term portfolio outcomes – a combination that is difficult to find in a single advisor. Paul holds a California and Texas real estate broker license and carries Series 22, 62, 63, and 82 securities licenses as a registered representative with Emerson Equity LLC, member FINRA /SIPC. He has represented buyers and sellers across complex commercial transactions, sourced and structured debt and equity, and worked alongside nationally recognized firms including Marcus Millichap, CBRE, JP Morgan, and Morgan Stanley. Before founding FGG1031, he co-founded Venture Navigation, a boutique investment banking firm whose M&A and IPO activity generated over $700 million in investor returns. Paul holds an MBA in Finance from the University of Michigan and a bachelor’s degree in chemistry from Wayne State University. He has also completed coursework in artificial intelligence at Stanford University. He is the author of four books on real estate investing and tax deferral strategy, including Tax Deferral Strategies Utilizing the Delaware Statutory Trust (DST) and Real Estate Investing in the New Era, both available on Amazon. A frequent speaker on 1031 exchanges, DST investing, and real estate tax strategy, Paul Getty is a recognized voice for investors and advisors seeking guidance on capital preservation through tax-deferred real estate investment.

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Disclaimer: There is no guarantee that any strategy will be successful or achieve investment objectives. All real estate investments have the potential to lose value during the life of the investments. This material does not constitute an offer to sell nor a solicitation of an offer to buy any security. Such offers can be made only by the confidential Private Placement Memorandum (the “Memorandum”). Please be aware that this material cannot and does not replace the Memorandum and is qualified in its entirety by the Memorandum.

This material is not intended as tax or legal advice so please do speak with your attorney and CPA prior to considering an investment. This material contains information that has been obtained from sources believed to be reliable. However, FGG1031, First Guardian Group, LightPath Capital, Inc., and their representatives do not guarantee the accuracy and validity of the information herein. Investors should perform their own investigations before considering any investment. There are material risks associated with investing in real estate, Delaware Statutory Trust (DST) and 1031 Exchange properties. These include, but are not limited to, tenant vacancies, declining market values, potential loss of entire investment principal.

Past performance is not a guarantee of future results: potential cash flow, potential returns, and potential appreciation are not guaranteed in any way and adverse tax consequences can take effect.  The income stream and depreciation schedule for any investment property may affect the property owner’s income bracket and/or tax status. An unfavorable tax ruling may cancel deferral of capital gains and result in immediate tax liabilities. All financed real estate investments have a potential for foreclosure. Delaware Statutory Trust (DST) investments are commonly offered through private placement offerings and are illiquid securities. There is no secondary market for these investments. Like any investment in real estate, if a property unexpectedly loses tenants or sustains substantial damage, there is potential for suspension of cash flow distributions. Costs associated with the transaction may impact investors’ returns and may outweigh the tax benefits.

IRC Section 1031, IRC Section 1033, and IRC Section 721 are complex tax codes; therefore, you should consult your tax and legal professional for details regarding your situation.

DST 1031 properties are only available to accredited investors (generally described as having a net worth of over one million dollars exclusive of primary residence) and accredited entities only (generally described as an entity owned entirely by accredited individuals and/or an entity with gross assets of greater than five million dollars). If you are unsure if you are an accredited investor and/or an accredited entity, please verify with your CPA and Attorney prior to considering an investment.

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FGG1031 | First Guardian Group and Emerson Equity LLC do not provide legal or tax advice. Securities offered through [Emerson Equity LLC](http://www.emersonequity.com/) Member [FINRA/SIPC](http://finra.org/) and MSRB registered. Emerson Equity LLC is unaffiliated with any entity herein.

1031 Risk Disclosure:

- There is no guarantee that any strategy will be successful or achieve investment objectives;
- Potential for property value loss – All real estate investments have the potential to lose value during the life of the investments;
- Change of tax status – The income stream and depreciation schedule for any investment property may affect the property owner’s income bracket and/or tax status. An unfavorable tax ruling may cancel deferral of capital gains and result in immediate tax liabilities;
- Potential for foreclosure – All financed real estate investments have potential for foreclosure; ·Illiquidity – Because 1031 exchanges are commonly offered through private placement offerings and are illiquid securities. There is no secondary market for these investments;
- Reduction or Elimination of Monthly Cash Flow Distributions – Like any investment in real estate, if a property unexpectedly loses tenants or sustains substantial damage, there is potential for suspension of cash flow distributions;
- Impact of fees/expenses – Costs associated with the transaction may impact investors’ returns and may outweigh the tax benefits

No offer to buy or sell securities is being made. Such offers may only be made to qualified accredited investors via private placement memorandum. Risks detailed in a private placement memorandum should be carefully reviewed, understood and considered before making such an investment. Prospective strategies and products used in any tax advantaged investment planning should be reviewed independently with your tax and legal advisors. Changes to the tax code and other regulatory revisions could have a negative impact upon strategies developed and recommendations made. Past performance and/or forward looking statements are never an assurance of future results.

Many of the investments offered will be only available to those investors meeting the definition of an Accredited Investor under SEC Rule 501(A) and offered as Regulation D private placement securities via a Private Placement Memorandum (“PPM”). Prospective investors must receive, read and understand all of the risks associated with buying private placement securities. Investments are not guaranteed or [FDIC](http://fdic.org/) insured and risks may include but are not limited to illiquidity, no guarantee of income or guarantee that all tax advantages or objectives will be met and complete loss of principal investment could occur.

**Risk Disclosure:** Alternative investment products, including real estate investments, notes & debentures, hedge funds and private equity, involve a high degree of risk, often engage in leveraging and other speculative investment practices that may increase the risk of investment loss, can be highly illiquid, are not required to provide periodic pricing or valuation information to investors, may involve complex tax structures and delays in distributing important tax information, are not subject to the same regulatory requirements as mutual funds, often charge high fees which may offset any trading profits, and in many cases the underlying investments are not transparent and are known only to the investment manager. Alternative investment performance can be volatile. An investor could lose all or a substantial amount of his or her investment. Often, alternative investment fund and account managers have total trading authority over their funds or accounts; the use of a single advisor applying generally similar trading programs could mean lack of diversification and, consequently, higher risk. There is often no secondary market for an investor's interest in alternative investments, and none is expected to develop. There may be restrictions on transferring interests in any alternative investment. Alternative investment products often execute a substantial portion of their trades on non-U.S. exchanges. Investing in foreign markets may entail risks that differ from those associated with investments in U.S. markets. Additionally, alternative investments often entail commodity trading, which involves substantial risk of loss.

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