721 UPREIT TAX PROTECTION REVIEW MATRIX Original educational organizer, not legal or tax advice. Repeat for each event. Attach the governing clause, not marketing language. Agreement name/version/amendments: ______ Protected holder and interest: ______ Protected asset/replacement treatment: ______ Proposed event/date: ______ Trigger definition/clause: ______ Effective/end dates: ______ Early termination/transfer terms: ______ Exclusions/consents: ______ Notice recipient/method/deadline: ______ Election or other condition: ______ Responsible person/next action/date: ______ Paying entity and obligation: ______ Calculation/gross-up/exclusions: ______ Payment timing/dispute route: ______ Required evidence and missing records: ______ Attorney questions: ______ CPA calculation questions: ______ Status: documented / unresolved / counsel review needed Do not treat a potential claim as available cash or an exemption from tax.