Rev. Proc. 81-4

Section 1. Background

Rev. Proc. 80-22, 1980-1 C.B. 654, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service.

Sec. 2. Procedure

Rev. Proc. 80-22 is hereby amplified by adding the following paragraph to section 3.01:

Section 856.--Definition of a Real Estate Investment Trust.--Whether a corporation whose stock is "paired" with or "stapled" to that of another corporation will qualify as a real estate investment trust under section 856 of the Code if the activities of the corporations are integrated.

Sec. 3. Effective Date

This revenue procedure will apply to all ruling requests on hand in the National Office on February 17, 1981, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as to requests received thereafter.

Sec. 4. Effect on Other Revenue Procedures

Rev. Proc. 80-22 is amplified.