DST vs TIC Comparison

DST Structure TIC Structure
IRS Guidance Rev. Rul. 2004-86 Rev. Proc. 2002-22
Number of Investors Up to 499 Up to 35
Ownership Percentage of beneficial ownership in a DST that owns real property Undivided tenant in common interest in real property
Investors receive property deed No Yes
Investors Form Single-Member LLC No Yes (generally)
Major Decision Approval No voting rights Equal voting rights and unanimous approval required
Number of Borrowers One (the DST) Up to 35
Bankruptcy Remote Yes No (Yes if using a single-member LLC)