IRS PLR: REIT’s Liquidation Sales Not Prohibited Transactions (IRC §857)

Sales of assets of a real estate investment trust (REIT) pursuant to a liquidation plan won’t be considered prohibited transactions under tax code Section 857(b)(6), the IRS ruled. The taxpayer represented that it intended to hold the assets (the “Properties”) for a certain minimum number of years but now sees a long decline in their value and, before pursuing complete liquidation, intends to explore alternatives that may allow it to continue holding the Properties. [PLR 201844003]

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