DALLAS-A new IRS ruling about corporate real estate isn’t for everyone and it’s not a “slam dunk,” Ernst & Young’s national director of real estate tax services tells GlobeSt.com.

It’s also not about saving tax dollars, says Michael Frankel, who is based in Dallas. That is secondary to the ability to strip corporate real estate from the balance sheet for a rosier outlook to gain access to more capital. A corporation attempting the REIT play should plan on spending a minimum of nine to 12 months to structure the tax-free transaction.

“It will be difficult to structure a transaction that meets all the factuals and satisfies all the business needs,” Frankel believes. “It’s clearly the national players that have substantial real estate holdings who should be looking at this.” By national, he means those corporations that have upward of $200 million in real estate holdings, specifically the big boxes and nationwide restaurant chains. Most REITs have portfolios in excess of $1 billion.

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