Late TRS Elections

IRS Private Letter Ruling 201214002

Internal Revenue Service Department of the Treasury
Washington, DC 20224
Number: 201214002
Release Date: 4/6/2012
Index Number:  9100.00-00, 856.07-00

Refer Reply To:

Dear ————-:

This is in reply to a letter dated June 10, 2011, requesting on behalf of Company and Sub an extension of time under section 301.9100-1 of the Procedure and Administration Regulations to file an election for Sub to be treated as a taxable real estate investment trust subsidiary (“TRS”) of Company under section 856(l) of the Internal Revenue Code.

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