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Introduction

SECTION 1. PURPOSE

Internal Revenue Bulletin 2014-37 · 2026-10-03 edition · updated 2026-10-04 · United States

This revenue procedure provides guidance regarding aspects of a taxpayer’s qualification as a real estate investment trust (REIT) in the context of transactions involving debt secured by real estate the fair market value of which has declined. This revenue procedure modifies and supersedes Rev. Proc. 2011–16, 2011–5 I.R.B. 440, to address situations in which there is a subsequent increase in the value of real property securing a loan addressed in Rev. Proc. 2011–16. Section 2.14(4) of this revenue procedure describes the modifications made by this revenue procedure to Rev. Proc. 2011–16.

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▸Contents — Internal Revenue Bulletin 2014-37

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