Type PLR Subject 2.07 - Non-Qualifying Income 20.04 - Other Keywords Foreign Currency Gains Functional Currency Other than U.S. Dollar Year 2008 IRS Link http://www.irs.gov/pub/irs-wd/0808024.pdf Summary § 988 income on the loans used to acquire assets from which qualifying REIT income is derived had sufficient nexus to be treated as qualifying REIT income. Title 200808024 Guidance Tags PLR - 200808024