1997-17

Type

PLR

Subject

10.00 - Qualified REIT Subsidiary (QRS)

7.03 - Built-in Gains

7.07 - Formation Transactions

Keywords

Built-in Gains, Tax on

Generally

Formation Transaction

Successor Corporation

phesluclushajowoniloneslatidot

1374

Qualified REIT Subsidiary

Deemed Liquidation of Existing Subsidiary at Time of Parent's REIT Election to Qualify as QRS

Subsidiaries Owned Prior to Parent's REIT Election

Not Always 100% Owned

Year

1997

Summary

IRS addresses conversion of partially-owned subsidiary into a TRS.

Title

9744004

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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.

1997-17

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