This discussion also does not consider any specific facts or circumstances that may be relevant to holders subject to special rules under the U.S. federal income tax laws, including, without limitation, certain former citizens or long - term residents of the United States, partnerships or other pass - through entities,
real estate investment trusts, regulated
investment companies, «controlled foreign corporations,» «passive foreign
investment companies,» corporations that accumulate earnings to avoid U.S. federal income tax, banks, financial institutions,
investment funds, insurance companies, brokers, dealers or traders in securities, commodities or currencies, tax - exempt organizations, tax - qualified retirement plans, persons subject to the alternative minimum tax, persons that own, or have owned, actually or constructively, more than 5 % of our
common stock and persons holding our
common stock as part of a hedging or conversion transaction or straddle, or a constructive sale, or other risk reduction
strategy.
Of course where asset protection
strategies and a more sophisticated
investment strategy is concerned,
real property can also be owned in a trust, a partnership, an LLC or other legal entity, and these are all
common alternatives for
real estate investment and development groups.
Most capital currently going into
real estate investment in these countries has an «opportunistic» risk / reward structure, but we expect that over the next few years «value - added» and «core»
strategies will become increasingly
common.