Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / reit-qualification-impact-memorandum.docx
reit-qualification-impact-memorandum.docx
Parties
HARKNESS LLP
Ashford Prewitt LLP
GMP Fairfield II LLC
GMP Westlake LLC
GMP Katy LLC
GMP Alliance LLC
GMP Lakeland LLC
GMP Southport LLC
Dates
November 20, 2023
May 31, 2024
June 6, 2024
June 30, 2024
September 15, 2020
July 1, 2028
February 1, 2021
March 1, 2029
November 22, 2019
December 1, 2030
Amounts
$1,100,000,000
$612,000,000
$488,000,000
$750,000,000
$74,800,000
$4.8
$33,446,000
$41,354,000
$1,098,930,000
$1,070,000
Obligations
Overview of Income Tests The Code imposes two gross income tests that a REIT must satisfy annually in order to maintain its REIT qualification: 75% Gross Income Test (Section 856(c)(3))
Section 856(d)(7) of the Code provides that if a REIT furnishes or renders services to the tenants of a property, or manages or operates the property, other than through (a) an independent contractor from whom the REIT does not derive or receive any income, or (b) a TRS of the REIT, then the services must be of a type "customarily furnished or rendered in connection with the rental of space for occupancy only
Accordingly, no TRS is required to provide tenant services at any of the 14 properties, and no impermissible tenant service income will arise from the Portfolio
To avoid the risk of impermissible tenant service income, the services provided by Fairwater PM must be of a type "customarily furnished or rendered in connection with the rental of space for occupancy only