1999-15

Type

PLR

Subject

2.02 - Interest

9.00 - Reorganizations

Keywords

Rents from Real Property

Related Party, Rents from

Momentary Ownership Disregarded

Generally

Related Parties

Momentary Ownership Disregarded

Reorganizations

Spin-offs (Section 355)

Year

1999

IRS Link

http://www.irs.gov/pub/irs-wd/9929010.pdf

Summary

A REIT’s momentary ownership of 100% of newly-formed subsidiary prior to its spin-off will not result in the disqualification from rental payments as "rents from real property".

Title

199929010

Guidance Tags

PLR - 199929010

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.

1999-15

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