Type PLR Subject 11.00 - Taxable REIT Subsidiary (TRS) 11.04a - Lodging Facilities Keywords Attribution Rules - Section 318 Eligible Independent Contractor Lodging Facilities Taxable REIT Subsidiary Attribution of Activities or Portfolio Investments Operation of Lodging Facility Year 2015 IRS Link http://www.irs.gov/pub/irs-wd/201533006.pdf Tax Report Link TaxReport (December 29, 2015) Summary Taxable REIT Subsidiary not Viewed as Operating Lodging Facility. Title PLR 201533006 Guidance Tags PLR - 201533006