Transcription of Taxable REIT Subsidiaries
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114114by Thornton MathesonTaxable REIT Subsidiaries : Analysis of the First Year'sReturns, Tax Year 2001 Thornton Matheson is a financial economist with theTreasury Department s Office of Tax Real Estate Investment Trust (REIT)Modernization Act, Part II, Subpart A ofPublic Law 106-170, the Ticket to Work andWork Incentives Improvement Act, enacted onDecember 17, 1999, created the Taxable REIT subsidiary (TRS), which allows a REIT to offer amore complete range of services to its tenantswithout jeopardizing its status as a REIT. The REITM odernization Act (RMA) also denied tax deductionsfor interest on loans from parent REIT s to TRS s incases of excessive leverage [1].The RMA mandated that [t]he Secretary of theTreasury shall conduct a study to determine howmany Taxable REIT Subsidiaries are in existence andthe aggregate amount of taxes paid by such subsid-iaries and submit its findings in a report to Congress[2].
115 Taxable REIT Subsidiaries: Analysis of the First Year's Returns, Tax Year 2001 income tax, but not to the regular REIT diversifica-tion tests.
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