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Home/Property Types/Raw Land

Raw Land

How farmland lease-income DSTs differ from non-income land-banking structures, and what entitlement risk, water rights, and depreciation treatment mean for a land DST investor.

Raw or unimproved land is uncommon as a DST offering because vacant land generates no rental income to distribute, which conflicts with the return profile most DST investors and sponsors are structured around. Where a land DST does exist, it is typically either agricultural land producing lease income from a farm operator, or a land-banking structure held for future development or sale, and the two have almost nothing in common as investments beyond both being unimproved real estate.

An exchanger considering land as replacement property should first confirm which of these structures a specific offering actually is, since a PPM describing a land holding needs to be read for how, if at all, it produces current income, and what the exit strategy and timeline actually depend on.

An agricultural land DST typically leases the property to a farm operator under a cash rent or crop-share arrangement, producing a modest but generally stable income stream tied to the land's productive capacity rather than to development potential. A land-banking DST, by contrast, is usually held with no current lease income at all, with the projected return dependent entirely on the property's value appreciating or being entitled and sold at a future date.

The PPM should state plainly whether the offering is income-producing or return-of-capital-plus-appreciation, since these are fundamentally different investment structures, and an investor expecting a regular distribution should confirm the offering actually pays one before subscribing.

For an agricultural land DST, the operator's farming experience, the lease's rent structure, and the land's soil quality and water rights are the core underwriting factors, closely paralleling how a farm lease would be evaluated outside a DST structure. A cash rent lease provides more predictable income than a crop-share lease, where the trust's income varies with harvest yields and commodity prices, and the PPM should specify which structure applies and disclose the operator's tenure and track record on the property.

Water rights and irrigation access, where applicable, materially affect both the land's productive value and its long-term marketability, and should be documented in the PPM rather than assumed from the property's general agricultural classification.

A land-banking DST held for future development value depends on entitlement, rezoning, or annexation processes that are controlled by local government bodies, not by the sponsor, and can take years longer than projected or fail entirely. The PPM should disclose the land's current zoning, what entitlement process, if any, is underway or planned, and what the projected exit assumes about the outcome and timing of that process.

Land held purely for appreciation without a specific entitlement plan is effectively a speculative holding, and the PPM's projected return in that scenario should be evaluated with more skepticism than a structure tied to a defined and already-permitted development path.

Land DSTs, particularly land-banking structures, typically carry longer and less certain hold periods than income-producing property DSTs, since the exit depends on finding a buyer at a favorable point in an entitlement or development cycle rather than simply refinancing or selling a stabilized, leased asset. An investor should treat a stated projected hold period for a land offering as considerably less reliable than the same disclosure for an apartment or retail DST, given how much the timeline depends on factors outside the sponsor's control.

Because no current distribution offsets the holding period in a non-income structure, the total return calculation depends entirely on the eventual sale price relative to acquisition cost, which makes the entry basis and the exit assumptions the two figures worth the most scrutiny.

Because raw land is not depreciable, a land DST does not generate the depreciation deductions that improved real estate does, which changes the after-tax comparison to other DST property types even before considering the income difference. This does not affect the exchange's qualification under Section 1031, but it does affect the tax profile of holding the DST interest, and an exchanger should discuss this distinction with a tax professional rather than assuming a land DST offers tax benefits comparable to an improved property.

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