The document discusses the tax status and implications for a company transitioning to a Real Estate Investment Trust (REIT) starting from the taxable year ended December 31, 2012. It includes an opinion from Goodwin Procter LLP regarding the company's qualification and taxation as a REIT, based on representations made by the company. The document outlines the tax benefits of being a REIT, such as avoiding double taxation, and the circumstances under which the company would still be subject to U.S. federal income tax.
doj/DataSet10/EFTA01384993.pdf
{"key_people":["Goodwin Procter LLP"],"document_type":"financial","document_subtype":"tax opinion","key_organizations":["Goodwin Procter LLP"],"reference_numbers":["DB-SDNY-0085774","SDNY_GM_00231958","EFTA01384993"]}