Content area
Full Text
Ltr. Rul. 20181005 addresses the application of Section 721(b), a corollary of the Section 351(e) investment company rules, to a contribution to a publicly traded partnership (X) holding substantially all the interests in a real estate investment trust (REIT).
Facts. In the transaction, X formed a new REIT by contributing substantially all its operating assets to the new REIT; subsequently, other partnerships that were partners in X planned to contribute additional operating assets to X, which it then contributed into the new REIT. The requested rulings were whether X's contribution of additional assets to the new REIT resulted in diversification...