IRS PLR: Taxable REIT Subsidiary Election Extension Granted (IRC §856)

The IRS has published a private letter ruling on IRC §856(l), granting the taxpayer and subsidiary an extension of time to jointly elect to treat the subsidiary as a taxable real estate investment trust (REIT) subsidiary (TRS) of taxpayer, effective on a specified date. Accordingly, the taxpayer and subsidiary have 90 calendar days from the date of the letter to make the intended election on Form 8875. [PLR 202527007]

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