Extract to table

02(1)(a), which provides that documentary stamp tax is imposed on "[d]eeds, instruments, or writings whereby any lands, tenements, or other real property, or any interest therein, shall be granted, assigned, transferred, or otherwise conveyed to, or vested in, the purchaser

Under Section 856(c)(4), at least 75% of a REIT's total assets (measured at the end of each calendar quarter) must consist of real estate assets, cash, cash items, and government securities

Section 1060 Allocation Under the entity-purchase structure, the aggregate Purchase Price of $1,100,000,000 must be allocated among the assets of each Target Entity for federal income tax purposes

This issue must be confirmed on a state-by-state basis by local counsel and the parties' respective accountants

The identity of the special servicer, the applicable pooling and servicing agreement, and the consent procedures applicable to securitized loans must be confirmed through due diligence