Marc Lane • Pete,
The IRS provides "real world" examples of PRIs through its Revenue Rulings and Private Letter Rulings (PLRs).
Below are a very few of many actual examples that provide insight as to how the IRS approaches the PRI analysis. In each case the IRS found a valid PRI.
* Revenue Ruling 78-90 (below market loan to assist blind persons secure employment)
* PLR 200136026 (investment in economic development)
* PLR 8710076 (investment in limited partnership that provides capital to other businesses)
* PLR 8141025 (low-income housing loan)
* PLR 8030079 (urban renewal loan)
* PLR 8301110 (construction loan in a blighted area)
* PLR 199943058 (below market-rate loan in foreign business)
* PLR 200043050 (deposit and loan guaranty)
* PLR 9033063 (participation interest in a letter of credit to secure favorable bond rating)
* PLR 8810026 (below market-rate loan to an insurance trust)
I hope you find this information helpful. Please let me know if I can be of any further assistance.