2004-25

Type

PLR

Subject

6.01 - Distributions - Generally

8.02 - Foreign Shareholders

20.00 - Miscellaneous

Keywords

United States Real Property Interest (USRPI)

Closely Held REITS

Foreign Shareholder

Liquidating Distribution

FIRPTA

Liquidation

Foreign-Controlled REIT

Year

2004

IRS Link

http://www.irs.gov/pub/irs-wd/0453008.pdf

Summary

Revocation of PLR 9016021, which had treated REIT liquidating distributions to foreign pension funds as distributions in exchange for stock rather than §897(h)(1) distributions.

Title

200453008

Guidance Tags

PLR - 200453008

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.

2004-25

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