1980

Type

PLR

Subject

2.01d - Rents from Real Property - 75% Income Test - Related Party Rents

20.03 - Paired Stock Arrangements

Keywords

Reorganizations

Paired/Stapled Entity

Stapled Stock

Year

1980

Summary

REIT and a lessee represent “stapled” stock so that the one set of shareholders own all stock in both entities, but no one person owns 10% of stock in both companies. The IRS ruled that rents paid by the lessee are qualifying income.

Title

8002026

Guidance Tags

PLR - 8002026

Referenced By

N/A

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What's a REIT?

REITs, or real estate investment trusts, are companies that own or finance income-producing real estate across a range of property sectors. These real estate companies have to meet a number of requirements to qualify as REITs. Most REITs trade on major stock exchanges, and they offer a number of benefits to investors.

Why Invest in REITs

REITs historically have delivered competitive total returns, based on high, steady dividend income and long-term capital appreciation. Their comparatively low correlation with other assets also makes them an excellent portfolio diversifier that can help reduce overall portfolio risk and increase returns. These are the characteristics of real estate investment.

About Nareit

Nareit serves as the worldwide representative voice for REITs and real estate companies with an interest in U.S. real estate. Nareit’s members are REITs and other real estate companies throughout the world that own, operate, and finance income-producing real estate, as well as those firms and individuals who advise, study, and service those businesses.

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