The key, it seems, is timing – the IRS will take a snapshot of the various agreements (including the ICT agreement) and determine whether they form a comprehensive partnership. Taxpayers who have questions regarding leases or similar exchanges should contact the Real Estate Group or the Hanson Bridgett LLP Tax Practice Group. The PLR analyzes different agreements between a landlord and a tenant that could become an ICT relationship. In particular, the IRS envisaged an ICT agreement (the „co-ownership agreement“) and a management agreement („management agreement“) that would only enter into force after both parties had entered into a lease agreement for the property (the „lease agreement“) and a call/put option for the lessee to purchase part of the property (the „option agreement“). .