An IPO of an UPREIT

1. Defers capital gains tax for property contributors the with respect to the properties contributed to the Operating Partnership.
2. Creates a non-marketable security that represents the property contributors residual interest in the entity that owns the REITs properties.
3. Does both (a) and (b).
4. Does neither (a) nor (b).

The primary attraction of non-exchange traded equity REITs is

1. Generally management that is considered superior to listed REITs
2. More detailed coverage by the analyst community
3. Greater total return (dividend + share appreciation) than listed companies
4. None of the above