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1997-05

Type
PLR
Subject
1.07 - Distribution of Accumulated C Corporation Earnings
10.00 - Qualified REIT Subsidiary (QRS)
9.00 - Reorganizations
Keywords
Dividends Paid Deduction
Distribution Funded by Promissory Note Treated as Dividend
Qualified REIT Subsidiary
Merger, Party to
Reorganizations
Pre-Acquisition Distributions of Acquired C Corporation
Year
1997
Summary

A corporation and the subsidiaries a REIT acquired in a reverse cash merger are considered qualified REIT subsidiaries and pre-acquisition dividends of the acquired corporation and its subsidiaries are a good distribution of C corporation earnings.

Title
9717036
Guidance Tags
PLR - 9717036
Referenced By
N/A