Washington Law Review


In 1960 Congress adopted §§ 856-858 of the Internal Revenue Code with the avowed purpose of granting to the small investor in real estate the same federal income tax advantages that are afforded investors in regulated investment companies. However the tax advantages that are granted have not given rise to a general adoption of organizations which qualify for the tax advantages. The major reasons for this lack of interest are the complexity of the sections themselves, problems raised by the regulations (many of which have been rectified by the final regulations which were adopted April 28, 1962), and problems raised by state law. This article will discuss the Real Estate Investment Trust with emphasis on Washington law, and will not discuss the problems of qualification under §§ 856-858 of the Internal Revenue Code since this subject has been covered by several articles.

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