The document discusses the tax implications and considerations for a REIT's operating partnership and its subsidiaries. It explains the classification of these entities for U.S. federal income tax purposes, the potential challenges from the IRS, and the impact on REIT qualification if these entities are treated as corporations instead of partnerships or disregarded entities. The document also covers the criteria for a partnership to be considered a 'publicly traded partnership' under Section 7704 of the Code.
doj/DataSet10/EFTA01384997.pdf
{"document_type":"legal"}