Don't hold your breath. Think about Plan B because the Treasury Department is going to announce that the deal violates the intent of the REIT tax exemption and not grant PZN the tax privilege. Too much ownership interest in the subsidiaries and the licensing arrangement is a clear scam.
or Treasury does. For what you say to be true, PZN would have to be getting OPCO's management income. As you may recall, Jonathan Litt, Cleo and others have explained how it's just the opposite - OPCO is going to steal income from PZN! Perhaps we can get them to testify in Tax Court how the market understands this much more clearly than the IRS.