company that manages a real estate portfolio for shareholders. To qualify for special tax treatment, a REIT must have a minimum of 100 beneficial owners and distribute at least 95% of its income. REITs distributing their income typically do not pay an entity-level tax and act as conduit for shareholder real estate investments. Income is taxed only once, and that at the beneficiaries' level. A trust is not permitted to be a personal holding company nor can it hold property mainly for sale to customers.