US: Service rules subpart F income qualifies under 95% REIT income test
June 1, 2011In PLR 201119001, the Service ruled that a REIT’s Subpart F Inclusions, Section 956 Inclusions, and PFIC Inclusions attributable to the REIT’s investments in foreign TRSs constitute qualifying income for purposes of the 95% income test of Section 856(c)(2).
Further details are available from the Ernst & Young International Tax Alert which can be accessed using the link below:
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