In 2004, the Internal Revenue Service (IRS) created a list of “seven deadly sins” for Delaware Statutory Trusts (DSTs) in Revenue Ruling 2004-86 (Rev. Rul. 2004-86). The revenue ruling describes how a DST holding only real...more
Revenue Ruling 2004-86 (July 20, 2004) held that (a) the Delaware statutory trust (“DST”) described therein qualifies as an investment trust under IRC §301.7701-4(c) that will be classified as a trust for federal tax...more