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2.38 MB
Extraction Summary
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People
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Organizations
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Locations
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Events
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Relationships
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Quotes
Document Information
Type:
Legal/tax policy document
File Size:
2.38 MB
Summary
This document details the federal tax treatment of Qualified REIT Subsidiaries (QRS) and Qualified Subchapter S Subsidiaries (QSub), explaining that they are generally disregarded as separate entities from their owners. It outlines exceptions to this rule, specifically focusing on employment and excise taxes, and discusses IRS Notice 99-6 and subsequent regulations regarding reporting methods for disregarded entities.
Timeline (3 events)
Issuance of Notice 99-6
Issuance of proposed regulations
Finalization of regulations in August 2007
Relationships (3)
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Key Quotes (4)
"In general, a QSub is not treated as a separate corporation for federal tax purposes."Source
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Quote #1
"A qualified real estate investment trust subsidiary (QRS) is a relatively specialized form of disregarded entity."Source
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Quote #2
"The number of exceptions and modifications to the general rule that DREs are treated as "tax nothings" has quietly increased over the last decade."Source
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Quote #3
"Reg. 301.7701-2(c)(2)(iv) treats eligible"Source
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Quote #4
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