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Form 851 Irvine California: What You Should Know
Incorporated in Delaware • Corporate headquarters: Irvine, California (1) The corporation's assets and the taxable income of, and the related taxable income or loss of the corporation's members, as computed under the internal revenue code of 1986, as amended (the “Code”); and (2) The corporation is a partnership, or a separate, disregarded-entry entity, (a) solely for the purpose of investing in tax-exempt property by way of partial or complete distributions, and (b) only because of the activities of the partnership or separate entity, as described in this paragraph, which are generally not taxed by this state or any political subdivision thereof, except that such investments are taxed by the state of New York on net income derived from such investments (including distributions and gains). (a) Any distribution or gain from the sale of the corporation's properties, stock, partnership interests, or other property, income, or gains therefrom, is generally taxed at graduated rates. For the purposes of this paragraph, the term “state of residence” means a state of the United States of America, its territories, or possessions, or a state, territory, or possession of the Commonwealth of Puerto Rico, and “state of residence” shall have the same meaning as in section 954 of title 26. The tax treatment of a partnership distribution of capital stock, shares, or other property, including such distribution from a REIT partnership, described in this section shall be the same as if the partner directly received the distribution from the partnership.
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