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TaxReport 2018-17

Type
PLR
Subject
2.00 - Income Tests - (75% & 95%)
2.01a - Rents from Real Property - 75% Income Test - Generally
2.08a - Generally
4.01 - 75% Test
4.01a - Real Estate Assets
Keywords
Asset Tests
75% Asset Test
Receivables
Gross Income
Defined
Items of Income Included
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856(c)(5)(J)
Income Tests
95%/75%
Section 856(c)(5)(J)
Year
2018
IRS Link
https://www.irs.gov/pub/irs-wd/201845001.pdf
Tax Report Link
Tax Report (Dec. 19, 2018)
Summary

Right to receive “brownfields” tax credit for environmental remediation is receivable that constitutes a qualifying real estate asset; income attributable to receipt of these tax credits is qualifying gross income for both REIT gross income tests