2024-12-18
Today we published a chart of PLR 200923001. This PLR concluded that a real estate investment trust (“REIT”) was “domestically controlled”. More than 50% of the REIT was owned by U.S. C corporations. However, those U.S. C corporations were wholly owned by foreign persons. This PLR was recently revoked in PLR 202449011, which is in line with the recent publication of final Treas. Reg. §1.897-1(c)(3)(iii)(B). This regulation provides a look-through rule for foreign-owned domestic C corporations.