The 200% rule is the identification path for an investor who wants a spread of smaller assets rather than a single large building. In Park City that usually means a mix of Main Street commercial condos, Kimball Junction retail pads, or a DST allocation, and the identification list has to be priced and packaged like a bid schedule before the 45-day window closes.
Instead of the three-property cap, the 200% rule permits identifying an unlimited number of replacement properties, provided the combined fair market value of everything on the list does not exceed twice the sale price of the relinquished property. There is no requirement to close on all of them, only that the written identification, delivered to the qualified intermediary inside the 45-day window, describes each property unambiguously.
Going even one dollar over the 200% cap on the identification list disqualifies the entire list unless the 95% rule is separately satisfied, so the valuation work on each candidate has to be done before the list is finalized, not after.
A 200%-rule list assembled for a Park City exchange often pairs a Main Street or Prospector commercial condo with one or two Kimball Junction retail or flex bays and a Delaware statutory trust allocation as a passive backstop. Pricing each line item against a realistic, financeable value matters more than pricing it optimistically, since an inflated valuation on any one property can push the aggregate over the cap.
Because inventory in a resort market this size is thin relative to a metro area, the list frequently draws candidates from both the Snyderville Basin corridor and the Heber Valley side of the Wasatch Back to keep enough qualifying options in front of the intermediary before day 45.
A list that leans too heavily on one submarket, such as several Main Street storefronts at similar price points, also concentrates risk if that corridor slows down all at once during the off-season. Spreading candidates across Kimball Junction, Snyderville Basin, and the Heber Valley side of the Wasatch Back gives the aggregate value some diversification alongside the cap discipline.
Yes, that is the point of the rule. Any number of properties can be listed as long as the combined fair market value stays at or under 200% of the START EXCHANGE REVIEW price, and only some of them need to actually close.
The entire identification list can be disqualified unless the investor separately satisfies the 95% rule by acquiring at least 95% of the aggregate value identified, which is a much narrower fallback and should not be relied on as a default.
It can serve as a passive backstop alongside active property candidates, though the DST's own offering terms and any associated debt should be reviewed with the investor's advisor before it is counted toward the aggregate value.
A smaller market can make it harder to assemble enough qualifying candidates inside 45 days, which is why Park City lists often pull in nearby Wasatch Back properties rather than staying limited to a single submarket.
The investor's broker or appraiser should confirm each value, and the investor's own tax advisor should review the aggregate math against the 200% cap before the list goes to the qualified intermediary.