By: Amanda Wilson Earlier this year, I discussed the IRS's recent no rule policy on spin-offs, and how that would likely have a chilling impact on spin-offs, particularly the common practice of businesses spinning off their real estate in a REIT...

By: Amanda Wilson On Monday, the IRS released Notice 2015-59. In it, the IRS announced that the IRS will no longer issue private letter rulings on whether a distribution satisfies the requirements of Section 355 for a tax-free spin-off where (i) the...

By: Amanda Wilson The IRS has released yet another private letter ruling (Letter 201522002) in the REIT area. This time, the IRS addressed the REIT treatment of income from the rental of outdoor advertising space (i.e., billboards). At issue were...

By: Amanda Wilson In order to qualify for the tax advantages available for real estate investment trusts ("REITs"), the majority of a REIT's assets must qualify as "real property". As the areas that REITs are investing in continue to grow, we are...