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Publication 938 Rev November Real Estate Mortgage Investment Conduits REMICs Reporting Information and Other Collateralized Debt

Publication 938 Rev November Real Estate Mortgage Investment Conduits REMICs Reporting Information and Other Collateralized Debt

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[Music] in Revenue ruling 90-112 domestic Corporation P owned 100% of foreign corporation s foreign corporation s was a controlled foreign corporation Corp s owned 25% of a partnership that in turn owned us real estate if Corp s had directly owned the US real estate it would have been an investment in US property under Section 956 an investment in US property can cause a deemed inclusion of the earnings of the Corp s to Corp P the ruling applied the aggregate approach to Partnerships as opposed to The Entity approach in applying the aggregate approach to Partnerships Corp s was considered to own 25% of the US real estate owned by the partnership this investment in US property by Corp s may have triggered a taxable inclusion to the US shareholder Corp p the

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