Taxation of Captive Real Estate Investment Trusts
Adopted in 2008, this model requires that a “captive REIT” add back its dividends paid deduction. A “captive REIT” is a REIT the shares or beneficial interests of which are not regularly traded and that has more than fifty percent of its voting power or value of its beneficial interests or shares owned or controlled by a single nonexempt corporation. (See also the model for Disallowance of Certain Payments to Captive REITs, below.)
Adopted Model (PDF)
Hearing Officer’s Report (PDF)