As previously announced in June 2012, the Board of Directors of Iron Mountain Incorporated (the "Company") unanimously approved a plan (the "Conversion Plan") for the Company to pursue conversion to a real estate investment trust ("REIT") under the U.S. Internal Revenue Code of 1986, as amended (the "Code"). The Company is in the process of implementing the Conversion Plan, pursuant to which the Company would elect REIT status no earlier than its taxable year beginning January 1, 2014.
As part of the Conversion Plan, the Company submitted requests for private letter rulings relating to its conversion to a REIT (collectively, "PLRs" and each a "PLR") to the U.S. Internal Revenue Service (the "IRS"). The PLR requests have multiple components, and the Company's conversion to a REIT will require favorable rulings from the IRS on a number of technical tax issues, including the characterization of the Company's racking structures as real estate (the "Racking Structure Request").
In June 2013, the Company disclosed that it had been informed by the IRS that the IRS had convened an internal working group to study the legal standards the IRS uses to define "real estate" for purposes of the REIT provisions of the Code and what changes or refinements, if any, should be made to those legal standards. The Company also disclosed that it believed that the IRS was unlikely to provide a definitive response to the Company's pending PLR requests, including the Racking Structure Request, until the working group concluded its study.
On November 14, 2013, the IRS informed the Company that the IRS will resume issuing rulings regarding the definition of "real estate" for purposes of the REIT provisions of the Code. The Company believes that the IRS is continuing to evaluate the Company's PLR requests, including the Racking Structure Request. At this time, the Company is not able to predict when the IRS will provide definitive responses to the Racking Structure Request or any additional outstanding PLR requests, and the Company does not intend to provide additional interim updates with respect to any of the specific Company PLR requests or, generally, the Company's progression through the IRS's PLR process.
The Company continues to move forward with other aspects of the Conversion Plan, including legal restructuring initiatives, the implementation of enterprise reporting system upgrades and testing of REIT-critical systems. The Company continues to work on the Conversion Plan to ensure readiness to elect REIT status beginning January 1, 2014; however, the Company can provide no assurance that it will be able to elect REIT status as of January 1, 2014, or at all.