MMM’s Aresh Homayoun was recently quoted in a Tax Notes article discussing an IRS letter ruling released on October 4, 2024.
The IRS addressed the application of gross income and asset tests established for REITs by section 856. The conclusion is that the REIT addressed in the ruling meets those tests even in the absence of any income of assets.
There was no speciļ¬c guidance from the IRS on that point until this ruling and “the lack of clear guidance has been less than ideal,” Aresh Homayoun of Morris, Manning & Martin, LLP said.
Read the full article here. A Tax Notes subscription is required.
