721 UPREIT
Contribution of DST interests into a REIT’s operating partnership in exchange for OP units — or, in some PPMs, a cash buyout.
Changes the tax reporting and usually the liquidity story. Private REITs control redemptions.
Why it shows up here: 4th & J exit talk is a 721 into Waterfall and/or a direct sale at 80–90 cents. The Vintage PPM (11 Jan 2022) states the same mechanics in the offering document: trustee may offer cash at independent appraisal or OP units in a REIT that may be sponsor-affiliated; investors do not approve; the trustee canvasses and is not bound. A private REIT can starve redemptions, often after a 24-month lock. Cash-out is not a put.