"could it actually be that fundamental, basic, cornerstone mistakes were made such that the OPCo/PZN relationship just simply won't work in its current state?"
Yep. The fundamental mistake is the REIT. Everything else wrong with the structure flows from that. Back in May or June, I wrote the 8 or 9 REIT myths, which were actually strategic errors in Doc's thinking (e.g. things that didn't go as planned) - thought it should have gotten a "nicster".
Actually, if PZN is going to be a REIT, this is the best structure. Can't see how to improve it. Seems to be one of those "can't live with it, can't live without it" situations.
Unfortunately, the structure is 100% tax driven. "Elegant" tax structures, also unfortunately, have no business being under public scrutiny.