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Tax Report 2013-10

Type
PLR
Subject
11.00 - Taxable REIT Subsidiary (TRS)
2.02 - Interest
4.01a - Real Estate Assets
4.02 - 10% Test
4.07 - Real Estate Assets - 25% Test - Generally
Keywords
Income Tests
95%/75%
Mezzanine Loans
Not a “Security”
Mortgage REIT
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
2013
IRS Link
http://www.irs.gov/pub/irs-wd/1315007.pdf
Tax Report Link
TaxReport2013-10
Summary

TRS mortgage loans and secured mezzanine loans are not securities for purposes of 25% value test

Title
201315007
Guidance Tags
PLR - 201315007