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.