2000-13

Type

TAM

Subject

2.02 - Interest

2.07 - Non-Qualifying Income

5.00 - Independent Contractor

7.07 - Formation Transactions

9.00 - Reorganizations

Keywords

Formation Transaction

Disguised Sale

phesluclushajowoniloneslatidot

355

707

Partnerships

Disguised Sale in Formation of Partnership

Reorganizations

Partnership to UPREIT

Year

2000

IRS Link

http://www.irs.gov/pub/irs-wd/0037005.pdf

Summary

Reconfiguration of a property-holding partnership into an UPREIT in connection with an IPO of a REIT results in a disguised sale.

Title

200037005

Guidance Tags

TAM - 200037005

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.

2000-13

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