Allocating UPREIT income to prevent REIT disqualification

Article Abstract:

Umbrella Partnership Real Estate Investment Trusts (UPREIT) have proliferated because they generally enable non-REIT investors who own real estate or interests in real estate partnerships to access REIT capital without suffering adverse tax consequences. Over the past few years, the IRS has addressed in letter rulings two issues that inevitably arise in using an UPREIT structure: 1. Will the REIT's management activities with respect to partnership properties cause rental income received by the REIT from either directly or owned properties or properties owned through operating partnerships to be characterized as something other than rents from real property? 2. Will fees that a REIT receives for managing partnership properties qualify as rents from real property?

Real estate investment trusts, Real Estate Invest Trusts, Economic policy, Varieties

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Expulsion Not Enforced Without Provision in Partnership

Article Abstract:

The Florida Supreme Court held that the law firm breached its fiduciary duty to the partner when it dismissed a partner to produce greater profits for the remaining partners.

Law firms, Executive dismissals, Florida. Supreme Court

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Reallocation of Partnership Income Sustained

Article Abstract:

Reallocation of a partner's income was disallowed by the Internal Revenue Services and its ruling was upheld by the Tax Court.

Partnership, Allocation (Accounting), Tax courts

Similar abstracts:

• Abstracts: Accounting Issues - Alocating Built-In Gains and Losses Following the Redemption of a Contributing Partner's Interest

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