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Introduction

SECTION 1. PURPOSE

Internal Revenue Bulletin 2018-40 · 2026-10-03 edition · updated 2026-10-04 · United States

This revenue procedure provides guidance regarding how certain items of income are treated for purposes of determining whether a real estate investment trust (REIT) satisfies the gross income test in § 856(c)(2) of the Internal Revenue Code (Code). The types of income addressed are—

  • Amounts required to be included in gross income under §§ 951(a)(1) (except by reason of § 965), 951A(a), 1291(a), 1293(a)(1), and 1296(a); and

Amounts required to be taken into account under § 986(c) as foreign currency gain with respect to distributions of previously taxed earnings and profits.

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▸Contents — Internal Revenue Bulletin 2018-40
Internal Revenue Bulletin 2018-40

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