The past is prologue: Do REIT qualification issues close with tax years, do they persist for ten (10) years (being the sum of five (5) years on account of the Section 856(g)(3) “lock out” plus another five (5) years of built-in gains tax exposure under Reg. § 1.337(d)-7), or do they live on forever (e.g., a “rolling” five-year lock out)?
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