The document is a legal opinion from Goodwin Procter LLP regarding the qualification and taxation of a company as a Real Estate Investment Trust (REIT). It outlines the conditions under which the company has been organized to meet REIT requirements and the limitations of the opinion, including its non-binding nature on the IRS and potential changes in law. It also discusses potential taxes the company may owe despite REIT status, including federal, state, local, and foreign taxes, as well as specific taxes on certain transactions and assets.
doj/DataSet10/EFTA01384947.pdf
{"key_people":["Goodwin Procter LLP"],"document_type":"legal","key_locations":["United States"],"document_subtype":"legal opinion","key_organizations":["Goodwin Procter LLP"]}