Private Letter Rulings

IRS Private Letter Ruling PLR 201408019

Taxpayer is a limited liability company that is treated as a partnership for federal income tax purposes. Taxpayer uses an overall accrual method of accounting for filing its federal income tax returns and uses an accounting period ending December 31. Taxpayer is owned X percent by DE, a disregarded entity for federal income tax that is wholly owned by LP, and Y percent by Management Co., a taxable real estate investment trust (“REIT”) subsidiary under § 856(l), which is also wholly owned by LP. LP is an affiliate of Trust, and Trust is a publicly held statutory REIT organized in State A that elected to be taxed as a REIT at all times beginning with Taxable Year 1. LP and Taxpayer are related under § 1031(f)(3).

IRS Private Letter Ruling PLR 200329021

Parent is a publicly-traded State A corporation that is engaged in the business of owning and operating C Facilities. Parent is the sole shareholder of several subsidiaries, including Taxpayer. Taxpayer holds title to approximately 100 fee-owned properties improved with C Facilities. These C Facilities are operated by Parent, which compensates Taxpayer for the use of the facilities. Parent files a consolidated federal tax return that includes Taxpayer, as well as its other wholly-owned subsidiaries.

IRS Private Letter Ruling PLR 200251008

Taxpayer is an S corporation, organized under the laws of State A, which operates Business on a calendar year basis, using the accrual method of accounting. Business is situated on RQ. Taxpayer owns a fee interest in RQ, with all improvements thereon.

IRS Private Letter Ruling 200148042

For Customer to obtain the benefits of the safe harbor rules of Rev. Proc. 2000-37, the transaction need only fit within the confines of the safe harbor rules. Assuming the boundaries of the safe harbor rules are not exceeded, Customer is entitled to enjoy the protection afforded to all compliant taxpayers by these rules, notwithstanding inconsistent treatment or characterization under state or local law.

IRS Private Letter Ruling 200236026

A, a wholly owned subsidiary of B, is engaged in the business of m. A, a calendar year taxpayer, files a consolidated income tax return as part of an affiliated group of corporations. All of the corporations in the affiliated group use the accrual method of accounting.

A’s business requires it to periodically dispose of certain properties and/or equipment, some of which is co-owned by other parties, and reinvest in like-kind property. A seeks to characterize the transactions as non-taxable exchanges under § 1031.

IRS Private Letter Ruling 200912004

Cars, light general purpose trucks (for use over the road having actual unloaded weight of less than 13,000 pounds) and vehicles that share characteristics of both cars and light general purpose trucks (e.g., crossovers, sport utility vehicles, minivans, cargo vans and similar vehicles) are of like kind for purposes of § 1031.

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