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IRS issues favorable REIT ruling on preferential dividends

  • Fox Rothschild LLP
  • -
  • USA
  • -
  • March 10 2011

In PLR 201109003 (3042011) the Service ruled, under the facts set forth in the request, that the proposed issuance of two classes of stock by a corporation which intended to meet the requirements of a real estate investment trust (REIT) would not cause distributions to stockholders to be treated as "preferential dividends" under Section 562(c) or otherwise jeopardize the corporation's qualification as a REIT