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2006-12

Type
PLR
Subject
11.01 - Generally
4.02 - 10% Test
4.05a - Generally
Keywords
Industrial Properties Services Rulings
Real Estate Asset
Loan to TRS Secured by Real Estate Not a "Security"
Taxable REIT Subsidiary
Loan Secured by Real Estate Not a "Security"
Year
2006
IRS Link
http://www.irs.gov/pub/irs-wd/0630010.pdf
Summary

Loans by a REIT to its TRS that were secured by real estate were not "securities" in the TRS for purposes of the 20% test of § 856(c)(4)(B)(ii).

Title
200630010
Guidance Tags
PLR - 200630010
Referenced By
N/A