Illegal Activity
none
Blackmail
none
Date
2012-12-31
Document Type
legal filing
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:43
Summary
This document discusses the company's status as a Real Estate Investment Trust (REIT) and the associated tax implications. It highlights the opinion of their tax counsel, Goodwin Procter LLP, regarding their qualification as a REIT, while also emphasizing that this opinion is not a guarantee and depends on ongoing compliance and potential changes in tax laws.
Metadata
- Subject
- REIT Status and Tax Implications
- Sender
- —
- Recipients
- —
- Document ID
- DB-SDNY-0085612
- Date
- 2012-12-31
Relationships 1
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| Goodwin Procter LLP | Legal Counsel | REIT | Goodwin Procter LLP provides legal opinion on REIT status. |
Notable Quotes 2
Our tax counsel, Goodwin Procter LLP, has rendered an opinion to us to the effect that (i) commencing with our taxable year ended December 31, 2012 we have been organized in conformity with the requirements for qualification and taxation as a REIT and (ii) our prior and proposed organization, ownership and method of operation as represented by management have enabled and will enable us to satisfy the requirements for qualification and taxation as a REIT for subsequent taxable years.
Accordingly, the opinion of our tax counsel does not guarantee our ability to qualify as or remain a REIT and no assurance can be given that we have satisfied and will satisfy such tests for our taxable year ending December 31, 2012 or for any subsequent period.
Red Flags 2
- The opinion of tax counsel is not a guarantee of REIT status.
- Potential for significant excise or penalty tax.
Financial Information
Amounts:S7,077,000S2,477,000
Transactions:
- Taxable disposition of assets
- Distribution to stockholders
Legal Compliance
- Potential failure to qualify as a REIT
- Risk of tax liabilities
- Dependence on ongoing compliance with REIT requirements
Raw Analysis JSON
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Themes
Financial transactions/money flowLegal matters/litigationBusiness dealings
Organizations 2
Goodwin Procter LLPIRS
Locations 1
United States
Text Analysis
- Tone
- Professional
- Purpose
- To inform about the REIT status, tax implications, and the opinion of tax counsel.
- Significance
- The document outlines the conditions and risks associated with maintaining REIT status, including potential tax liabilities and reliance on legal counsel's opinion.
File Info
- File Name
- EFTA01384947.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:43:39.922351
- DOJ Source
- View on DOJ