Revenue Ruling 2004-86
The 2004 IRS ruling that interests in a Delaware Statutory Trust can be treated as direct interests in real property for 1031 purposes if the trust follows strict operating limits.
Nashional Investments · Updated October 2026
Educational definition only, not investment, tax or legal advice.
In practice
In a 1031 exchange, small details decide whether the full gain is deferred: the identification deadline, the value and debt you replace, and who holds the sale proceeds. The term Revenue Ruling 2004-86 comes up when we review an exchange or a Delaware Statutory Trust offering with a client. We read the offering memorandum, check the sponsor's track record and fees, and confirm the replacement fits the exchange rules before anything closes.
Common questions.
What does the term Revenue Ruling 2004-86 mean?
Why does Revenue Ruling 2004-86 matter for investors?
See how this fits into a real plan on our 1031 exchanges and DSTs page.
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