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1998-05

Type
PLR
Subject
10.00 - Qualified REIT Subsidiary (QRS)
2.01 - Rents from Real Property - 75% Income Test
2.01b - Rents from Real Property - 75% Income Test - Permissible Services
2.02a - Obligations secured by Mortgages or Interests in Real Property (75% Test Interest)
2.07 - Non-Qualifying Income
2.08a - Generally
2.08b - Warrants
4.00 - Asset Tests
4.01a - Real Estate Assets
4.04 - Third Party Service Subsidiary (Preferred Stock Subsidiary)
Keywords
Asset Tests
75% Asset Test
Deferred Purchase Money Obligation
Common Area Maintenance
Cleaning Public Entrances, Exits, Stairways, Walkways, Lobbies, Restrooms, Snow Removal, Trash Collection, Pest Control and Painting (Each May Not Be Present in All Rulings)
Construction/Improvements
Administrative Functions (Including Hiring and Supervision of Contractors; Obtaining Permits; Addressing Zoning Laws; Reviewing Plans; Ordering Materials)
Fire Protection Systems (Alarms, Sprinklers)
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708
Interest (Received) Income
Contingent Interest
Other Interest (95% Income)
Landscaping
Non-Qualifying Income
Qualified REIT Subsidiary
Deemed Liquidation of Existing Subsidiary at Time of Parent's REIT Election to Qualify as QRS
Real Estate Asset
Contingent Interest Obligation
Rooftops
Rents from Real Property
Easement Agreements
Lease Space/Utilities to Service Provider
Rooftop, to Telecommunications Providers
Common Areas
Advertisements
Antennae, Space for
Third-Party Service Subsidiary
Agent of REIT, Treated as
No Ruling Policy, IRS
Utilities
Generally (Electric, Gas, Water, Sewer)
Year
1998
Summary

Shares of amounts received from pay telephones, antennae ad advertisements qualify as "rents from real property." Portion of REIT's interest in project manager will be disregarded for purposes of REIT income tests.

Title
9808011
Guidance Tags
PLR - 9808011
Referenced By
N/A