In a generic legal advice memorandum (AM 2023-003 or GLAM), the IRS Office of the Chief Counsel addressed the application of the regularly traded stock exception under IRC Section 897(c)(3) to stock of a United States real property holding corporation (USRPHC) held by a partnership. The IRS concluded that the 5% ownership test (10% for real estate investment trusts (REITs)) should apply at the par…