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

A real estate investment trust (“Taxpayer”) and its subsidiary received extra time to file an election under tax code Section 856(l) for the subsidiary to be treated as a taxable REIT subsidiary (TRS) of Taxpayer. According to the representation, an outside law firm and an outside accounting firm, which Taxpayer and Parent engaged to provide advice including such as related to the TRS election, each believed that the other was responsible for filing the necessary forms — Form 8832, Entity Classification Election, and Form 8875, Taxable REIT Subsidiary Election — leading to failure to file the forms. [PLR ...