721 UPREIT Pros: investment-company exception review 1. Name the receiving partnership. 2. Identify contributed property or interest. 3. Request current asset classification and valuation support. 4. Obtain the planned transaction sequence. 5. Request the scoped Section 721(b) tax analysis. 6. Ask your CPA and attorney to review assumptions and unresolved facts. 7. Assign updates before closing. For each item record document/date, reviewer, open question, responsible party and next step. Keep liability, cash, basis, fees and liquidity reviews separate. No tax or investment result is guaranteed.