During 2019, the IRS issued private letter rulings to real estate investment trusts (REITs).
Tax professionals know that each private letter ruling is written for a taxpayer’s specific facts and is precedent only for that taxpayer; pursuant to section 6110(k)(3), a private letter ruling “may not be used or cited as precedent” by other taxpayers. As a practical matter, tax professionals also realize that a private letter ruling provides an indication of the IRS’s position on the issues addressed. Thus, it is not uncommon for tax professionals advising REITs to consider private letter rulings because REITs are subject to various qualification requirements for which published guidance may be limited. Thus far during 2019, the IRS released private letter rulings in which the IRS ruled that:
Read a November 2019 report [PDF 102 KB] prepared by KPMG LLP: What’s News in Tax: What’s new for REITs: Private letter rulings in 2019
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