2000-09

Type

PLR

Subject

7.07 - Formation Transactions

9.00 - Reorganizations

Keywords

Formation Transaction

Diversification

phesluclushajowoniloneslatidot

Partnership to UPREIT

Public Master Limited Partnership into a New REIT

Transfer of Property to REIT

Section 351(e)

Year

2000

IRS Link

http://www.irs.gov/pub/irs-wd/0011036.pdf

Summary

Transfer of a publicly traded partnership and its affiliates’ already diversified portfolio of real estate to a REIT that was considering a subsequent public offering was governed by § 351(a), not § 351(e).

Title

200011036

Guidance Tags

PLR - 200011036

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.

2000-09

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