umbrella partnership real estate investment trust

A REIT that controls and holds most of its properties through an umbrella limited partnership, as a result of which the trust can acquire properties in exchange for the limited-partnership interests in the umbrella while triggering no immediate tax obligations for certain sellers.

• This is a structure that many REITs now use. — Abbr. UPREIT. [Cases: Internal Revenue 3997. C.J.S. Internal Revenue § 420.]

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