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 Guidance Tags PLR - 9744004 Referenced By N/A