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2008-18

Type
PLR
Subject
11.00 - Taxable REIT Subsidiary (TRS)
11.06 - Taxable REIT Subsidiary - Eligible Independent Contractor
Keywords
Taxable REIT Subsidiary
Eligible Independent Contractor
Actively Engaged in Trade or Business of Operating Qualified Lodging Facilities
Eligible Independent Contractor
Lodging Facilities
Year
2008
IRS Link
http://www.irs.gov/pub/irs-wd/0825034.pdf
Summary

IRS held that IK owned by REIT's executives engaged in "active conduct" of managing qualified lodging facilities; thus, rent paid by REIT's TRS for the facilities was not "related party rent."

Title
200825034
Guidance Tags
PLR - 200825034