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