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PLR 201939001

Type
PLR
Keywords
Asset Tests
Partnerships
REIT Determines Assets Held through Partnership through 1.856-3(g)
Year
2019
IRS Link
https://www.irs.gov/pub/irs-wd/201939001.pdf
Tax Report Link
Review of 2019 REIT-Related Private Letter Rulings
Summary

REIT determines its capital interest in a partnership under Treas. Reg. 1.856-3(g) by a) deeming the partnership to have made a liquidating distribution in an amount equal to the fair market value of the partnership assets, net of the partnership liabilities, and, b) computing the percentage of the deemed distribution to which the REIT would be entitled under the terms of the partnership agreement.

Title
PLR 201939001