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Strategies & Market Trends : Arbitrage Plays
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To: Allen Furlan who wrote (264)10/24/2000 4:09:32 PM
From: David Lee Smith   of 376
 
I did some research into this idea. There was a bill to prohibit tax-free exchanges or mergers between REITs and non-REITs that died and it's not likely to resurface as an issue. On the other hand, PCL actually got a favorable letter ruling from the IRS to change from a MLP to a REIT to enable a tax-free merger into TGP. The merger is contingent upon a favorable letter ruling from the IRS on the tax-free status of the merger. This deal has been in the hopper since early 1999, and it has some very high powered attorneys and financial advisors (including Goldman Sachs) that have looked at the deal and its tax consequences. A negative letter ruling would be making new law, something the IRS is loath to do. I expect a favorable letter ruling from the IRS and a deal that gets done.
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