UPREITs The Straight Dope Please

[Mary Lea McTurnan]

A situation: Several trusts ending, soon. A couple contain prime Development ground. 2 siblings are remaindermen. They have very different approaches to business. Could the proceeds from a few large development sales be 1031d to an UPREIT and then liquidated at step-up, easily and separately , by the siblings upon trust termination ? What can be expected regarding range of loads for UPREIT participants, and is this a valid strategy to bifurcate some assets without triggering a massive tax event ? Thank you