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

A real estate investment trust (“Parent”) and its acquired subsidiary received extra time to jointly elect under tax code Section 856 to treat Subsidiary as an association taxable as a corporation and as a taxable REIT subsidiary (TRS) of Parent as of the intended date, following Parent’s discovery that an invalid Employer Identification Number (EIN) was entered for Subsidiary on timely filed forms. According to the representation, a Form 8832, Entity Classification Election, and a Form 8875, Taxable REIT Subsidiary Election, were prepared based on information provided by the seller in conjunction with the acquisition transaction. [PLR ...