Milestone Apartments REIT will be a dual (Canadian/U.S.) REIT

Milestone Apartments REIT, a Canadian REIT, will be a U.S. corporation under the Code s. 7874 anti-inversion rules.  However, it will elect to also be a U.S. REIT so as to avoid U.S. corporate income tax.

Neal Armstrong.  Summary of Milestone Apartments REIT under Cross-Border REITS.