According to NAREIT, “real estate investment trusts,” or REITs, own more than $3 trillion of U.S. real estate assets. With REITs having survived (and, in some respects, thrived) under recent tax reform, that number likely will rise in the ensuing decade. But what does it mean that REITs hold so much real estate? In part, it means owning and operating real estate through the prism of Section 856 et seq of the Internal Revenue Code, a complex web of tax laws enacted in 1960 to create the REIT and facilitate real estate investment by the public.