2012-20

Type

PLR

Subject

11.04a - Lodging Facilities

11.05 - Related Party Rent

11.06 - Taxable REIT Subsidiary - Eligible Independent Contractor

2.01a - Rents from Real Property - 75% Income Test - Generally

2.01d - Rents from Real Property - 75% Income Test - Related Party Rents

Keywords

Billboard Rentals

Eligible Independent Contractor

Hotel Management Service

Rents from Real Property

Taxable REIT Subsidiary

Year

2012

IRS Link

http://www.irs.gov/pub/irs-wd/1225008.pdf

Tax Report Link

TaxReport2012-20

Summary

Third party manager is eligible independent contractor, TRS is not operating hotel, and TRS' rental payments are qualifying rent to REIT.

Title

201225008

Guidance Tags

PLR - 201225008

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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.

2012-20

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