SECTION 8. NO INFERENCE

.01 No inferences should be drawn about whether similar consequences would obtain if an arrangement takes actions that fall outside the limited scope of this revenue procedure.

.02 Thus, an arrangement’s qualification as a trust under § 301.7701-4(c) may be affected by a waiver or deferral of rent (and related modifications) that is inconsistent with section 3.03 of this revenue procedure and the lease arrangement described in Rev. Rul. 2004-86.

.03 Similarly, contributions that are not described in section 6.04 of this revenue procedure are outside the scope of the safe harbor in section 7 of this revenue procedure. For example, the scope of the safe harbor does not include additional contributions to the trust that are used to make more than minor, non-structural modifications to the trust’s real property. Additionally, contributions of property other than cash generally manifest a power to vary.