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Structured Installment Sale Resource Center
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Chapter 6 · The Structure

SIS vs. Other Deferral Strategies

Comparing the Structured Installment Sale to §1031 exchanges, Opportunity Zones, CRTs, DSTs, and monetized installment sales.

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Content reviewed October 17, 2026 · Educational reference

How the SIS compares to 1031 exchanges, Opportunity Zones, DSTs, CRTs, plain seller notes, and a taxable lump sum.

In plain English

The SIS is one of several ways to soften the tax hit on a big sale. A 1031 exchange defers tax but only for real estate bought on a tight clock. Opportunity Zones reward a 10-year investment but put capital at market risk. A Deferred Sales Trust generally uses an intermediary trust that buys for a note and then sells to the ultimate buyer; a monetized installment sale borrows against the note for cash now — two different structures, both drawing IRS scrutiny in their aggressive forms. A Charitable Remainder Trust is powerful but irrevocable and charity-focused. The SIS trades liquidity for contractually fixed, insurer-funded income and broad asset eligibility — with tax treatment dependent on eligibility, documents, actual rights, and the complete transaction.

The master comparison

DimensionStructured Installment Sale (SIS)Section 1031 ExchangeOpportunity ZoneDeferred Sales TrustMonetized Installment SaleCharitable Remainder Trust (CRT)Lump Sum Taxable Sale
Asset eligibilityBroad capital assetsReal property onlyCapital gains → fundBroadBroadBroadAny
LiquidityLow (illiquid)Low (in property)Low (10-yr hold)Low–moderate (trust income)High (loan against note)Income onlyHighest
Income streamContractually fixed periodic (insurer-funded)Property cash flowFund distributionsTrust distributionsLoan now + installmentsAnnuity/unitrustNone
Credit riskAssignment-company and insurer credit; contract-specific guaranteesMarket/tenantMarketTrust investment riskLender + tax riskTrust investmentsN/A
ComplexityModerateModerateHighHighHighHighLowest
Legal certainty§453 statutory framework; funded assignment requires analysisHigh (statutory)HighModerate (IRS scrutiny)High tax risk; listed-transaction designation proposed in sources reviewedHighHigh
Business-sale fitStrongNoLimitedPossibleHigh riskPossibleYes

Strategic selection framework

  1. Want to stay invested in real estate? Consider a 1031 exchange or a QOF.
  2. Charitably inclined and want a deduction? Consider a CRT.
  3. Comfortable with market risk for 10 years? Consider an Opportunity Zone fund.
  4. Want to exit and receive scheduled insurer-funded income? Consider an SIS when the asset, payment terms, credit exposure, and after-tax projection fit the seller’s needs. Eligibility and legal analysis remain necessary.
  5. Need all cash now? A cash sale supplies liquidity. A conventional seller note is a separate alternative for someone willing to accept deferred payments and buyer credit risk.
A word on "too-good-to-be-true" deferral

Two structures the SIS is often confused with are distinct from it and from each other. A Deferred Sales Trust typically involves a sale to an intermediary trust for a note followed by the trust’s sale to the ultimate buyer; receiving cash and then depositing it into a trust does not undo receipt. A monetized installment sale pairs claimed deferral with near-term borrowing and is the subject of proposed listed-transaction regulations and enforcement. Genuine deferral and absence of a loan are relevant SIS facts, but neither supplies automatic approval or eliminates every possible disclosure obligation.

Disambiguate the initials DST

A Delaware statutory trust holding real estate and a marketed Deferred Sales Trust installment arrangement are different. Neither label by itself determines federal tax treatment. Identify the actual transaction before comparing investment risk, tax rules, or fees.

Use the right law for the transaction date

The 2025 legislation changed §1202 and Opportunity Zone rules and added §1062 for qualifying farmland sales. Avoid applying an old comparison chart to every new transaction. See alternatives after 2025 for the key date distinctions.

Sources: IRC §453 — installment method; IRC §1031 — like-kind real-property exchanges; IRC §1202 — qualified small business stock; IRC §1400Z-2 — Opportunity Zone investments; IRC §1062 — qualified farmland tax-payment election; Federal Register — proposed monetized-sale listing regulations.

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