IRS PLR: Taxable REIT Subsidiary Election Extension Granted (IRC §856)

Taxpayer and subsidiary granted extension of time to file Form 8875, Taxable REIT Subsidiary Election, to treat subsidiary as a taxable REIT subsidiary (TRS) of Taxpayer under I.R.C. §856(l) effective as of the date subsidiary was formed. According to the representation, Taxpayer intends to elect to be a real estate investment trust (REIT) beginning with its first taxable year and to engage an eligible independent contractor or contractors to operate a hotel on its behalf. Taxpayer’s internal tax department prepared and filed forms related to the request for relief before the failure . Granting the relief won’t result ...