b'Each DST has a Signatory Trustee (manager of the trust) and a Delaware Trustee. The Depositor and Signatory Trustee are both 100% owned by the sponsor of the deal (you). The DST holds title on its own or through a wholly owned subsidiary entity. DST beneficiaries have the same limitation on personal liability as do shareholders in a Delaware corporation. Because of this, they can take title to their beneficial interests individually and are treated as if they own undivided interests in the underlying real estate for federal tax purposes. The DST will typically have a Master Lease Agreement with a third party Lessee so that the Master Lessee can negotiate leases (remember, the DST cant do this on its own). The sponsor (or an Affiliate) can be the Lessee; however, the Master Lessee cannot refinance the property. If it does, the DST will convert to a limited liability companywhich could trigger taxation of the 1031 Exchange investors/beneficiaries. Yikes! The structure may include a Springing LLC with a pre-written operating agreement that the trustee can invoke and convert the DST to a limited liability company if the property is in danger of being lost due to DST limitations; doing this would allow additional funds to be raised or to attract better financing or negotiate new leases. All of this is great for attorneys because there are lots of legal documents to create, but it will drive up the legal costs and time needed to get the deal 182'