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Developments

IRS Looks at QRS
[November/December, 2000]

Stefan Tucker

Stefan F. Tucker of Venable, Baetjer, Howard & Civilett; in Washington, DC presented testimony on behalf of the National Association of Real Estate Investment Trusts (NAREIT) and The Real Estate Roundtable to the Internal Revenue Service and Treasury Department on August 8. The testimony proposed regulations that address tax-free reorganizations involving disregarded entities, including qualified REIT subsidiaries (QRS). NAREIT had not testified before the Internal Revenue Service for at least a decade, but this was the second time this year. NAREIT's Government Relations Committee organized a task force to analyze the proposed regulations. Based on the task force's recommendations, Tucker testified that the regulations should be changed to make it easier for REITs to qualify using tax-free organizations involving a QRS, as under prior IRS private letter rulings.


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