29 October 2010 External T.I. 2007-0244171E5 - SIFT Trust SIFT Partnership -- summary under Rent from Real or Immovable Properties

A net lease of a hotel or retirement residence by a trust to an arm's length operator thereof generally would qualify as giving rise to qualifying rents .

However, a percentage participation under the lease in the gross revenues of the tenant would cause all of the rents of the landlord trust to not qualify as "rent from real or immovable properties", if such revenues of the tenant did not themselves qualify as "rent from real or immovable properties", eg., revenues for the use of hotel rooms.

Topics and taglines
Tagline
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
318675
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
342021
Extra import data
{
"field_editor_tags": [],
"field_roundtable_subquestion": "",
"field_stub": false,
"field_legacy_header": "29 October 2010 T.I. 2007-0244171E5 [qualifying non-participating rent under hotel lease]"
}
Workflow properties
Workflow state