Alan Fischl, Tax Partner in the Washington office of PriceWaterhouseCoopers, covered a number of international tax matters, including dual consolidated losses, stapled stock
, worthless stock deductions and the S.
The management of First Union continues to work through the proper channels in Washington to preserve as many of the benefits of the stapled stock
structure as possible.
First Union's parking acquisition program is designed to secure the maximum economic benefit from the company's rare tax status, known as a stapled stock
structure, which allows it a greater range of business and
367(b)-2(g) provides that the deemed conversion of a foreign corporation to a domestic corporation under the stapled stock
rules of section 269B is considered an F reorganization for purposes of the section 367(b) regulations.
We also believe that the parking industry represents an ideal platform from which to take advantage of our unique stapled stock
structure," Mastandrea continued, "whereby our shareholders benefit not only from the Trust's ownership of parking facilities but also from the income generated by our management company operating those facilities.
Founded in 1961, First Union Real Estate Investments is a real estate investment trust (REIT) that has a unique stapled stock
structure with its management company.
Mastandrea said the Trust has been a long-term investor in parking facilities and recognizes the opportunity to create a critical mass of assets, taking advantage of economies of scale and industry trends toward outsourcing and privatization which will give a larger owner/operator like First Union, with its stapled stock
structure, a distinct competitive advantage.