IRS PLR: Consent Granted for Taxpayer to Be Treated as if REIT Election Not Made (IRC §856)

Consent granted for Taxpayer to be treated as if it had not made an election to be a real estate investment trust (REIT) on its Form 1120-REIT, US Corporation Income Tax Return for REITs, inadvertently filed for a certain taxable year, the IRS ruled. Taxpayer was formed to invest in single family residences and anticipated making the REIT election when it met the requirements to be treated as a REIT. However, Taxpayer determined through discussions with Tax Consultant and Legal Counsel that Taxpayer didn’t meet the requirements for the election, and therefore, filed a return for the year at ...