Thanks so much...here's a repost of the information on upreit's:
There's a pretty detailed explanation of UPREIT's (and the tax advantages) at:
The UPREIT structure was created to avoid recognition of taxable
income on the transfer of appreciated property to a REIT... UPREITs
have accounted for nearly two-thirds of all newly formed REITs since
1992. Today, over half of the largest REITs are organized as UPREITs.
In a typical UPREIT structure, one or more individuals and/or
partnerships owning real estate contribute their holdings to an
"umbrella partnership" in exchange for limited partnership units,
sometimes called operating partnership units. Contemporaneously, a
REIT is formed and issues shares to the public. The REIT then
contributes the proceeds received from the REIT shareholders to the
umbrella partnership in exchange for a general partnership interest.
The proceeds are used to reduce debt or acquire additional property or
used for any other REIT purposes. The limited partners also receive
rights to "put" their partnership interest to the umbrella partnership
or to the REIT in exchange for cash or REIT shares....
Before rating this answer, please let me know if you need any
additional information on this topic.
All the best,