2024-12-18
Today we published a chart of PLR 200923001. This PLR concluded that a real estate investment trust ("REIT") was "domestically controlled". More than 50% of the REIT was owned by U.S. C corporations. However, those U.S. C corporations were wholly owned by foreign persons. This PLR was recently revoked in PLR 202449011, which is in line with the recent publication of final Treas. Reg. §1.897-1(c)(3)(iii)(B). This regulation provides a look-through rule for foreign-owned domestic C corporations.
DISCLAIMER
The posts on this blog have not been verified for accuracy. You should consult an attorney for legal advice regarding your own situation. These posts are not updated for changes in the tax laws. Further, these posts should not be relied upon for any purpose whatsoever.
Copyright © 2004 – 2026, Andrew Mitchel LLC. All rights reserved.