The fundamental definition of a REIT is a matter
of corporate structure and charter. PZN became a
REIT in the last reorganization, and will remain so
until the shareholders vote to make a change, if they
do.
This is not to be confused with qualifying for special
tax benefits only available to REITs. PZN has failed
to meet those standards, and will as a result be
taxed the same way a c-corp is taxed.
Another
way to look at this is that the IRS determines
whether and how PZN is taxed, but only the shareholders
determine corporate structure. PZN ***may*** be a REIT
without the tax benefits of retaining that type of
corporate organization.