Common use of Real Estate Investment Trust Clause in Contracts

Real Estate Investment Trust. The Company has been organized and has operated in conformity with the requirements for qualification and taxation as a real estate investment trust (a “REIT”) under the Internal Revenue Code of 1986, as amended (the “Code”), for its taxable years ended December 31, 2010 through December 31, 2015, and the Company’s organization and method of operation (as described in the Registration Statement, the General Disclosure Package and the Prospectus) will enable the Company to continue to meet the requirements for qualification and taxation as a REIT under the Code for its taxable year ending December 31, 2016 and thereafter. All statements regarding the Company’s qualification and taxation as a REIT set forth in the Registration Statement, the General Disclosure Package and the Prospectus are correct in all material respects.

Real Estate Investment Trust. The Company has been organized and has operated in conformity with the requirements for qualification and taxation as a real estate investment trust (a “REIT”) under the Internal Revenue Code of 1986, as amended (the “Code”), for its taxable years ended December 31, 2010 through December 31, 20152013, and the Company’s organization and method of operation (as described in the Registration Statement, the General Disclosure Package and the Prospectus) will enable the Company to continue to meet the requirements for qualification and taxation as a REIT under the Code for its taxable year ending December 31, 2016 2014 and thereafter. All statements regarding the Company’s qualification and taxation as a REIT set forth in the Registration Statement, the General Disclosure Package and the Prospectus are correct in all material respects.

Real Estate Investment Trust. The Company has been organized and has operated in conformity with the requirements for qualification and taxation as a real estate investment trust (a “REIT”) under the Internal Revenue Code of 1986, as amended (the “Code”), for its taxable years ended December 31, 2010 through December 31, 20152014, and the Company’s organization and method of operation (as described in the Registration Statement, the General Disclosure Package and the Prospectus) will enable the Company to continue to meet the requirements for qualification and taxation as a REIT under the Code for its taxable year ending December 31, 2016 2015 and thereafter. All statements regarding the Company’s qualification and taxation as a REIT set forth in the Registration Statement, the General Disclosure Package and the Prospectus are correct in all material respects.

Real Estate Investment Trust. The Commencing with its taxable year ended December 31, 2010, the Company has been organized and has operated in conformity with the requirements for qualification and taxation as a real estate investment trust (a “REIT”) under the Internal Revenue Code of 1986, as amended (the “Code”), for its taxable years ended December 31, 2010 through December 31, 2015, and the Company’s organization and proposed method of operation (as described in the Registration Statement, the General Disclosure Package and the Prospectus) will enable the Company to continue it to meet the requirements for qualification and taxation as a REIT under the Code for its taxable year ending December 31, 2016 and thereafter. All statements regarding the Company’s qualification and taxation as a REIT and descriptions of the Company’s organization and proposed method of operation (inasmuch as they relate to the Company’s qualification and taxation as a REIT) set forth in the Registration Statement, the General Disclosure Package and the Prospectus are correct accurate and fair summaries of the legal or tax matters described therein in all material respects.

Real Estate Investment Trust. The Commencing with its taxable year ended December 31, 2010, the Company has been organized and has operated in conformity with the requirements for qualification and taxation as a real estate investment trust (a “REIT”) under the Internal Revenue Code of 1986, as amended (the “Code”), for its taxable years ended December 31, 2010 through December 31, 2015, and the Company’s organization and proposed method of operation (as described in the Registration Statement, the General Disclosure Package and the Prospectus) will enable the Company to continue it to meet the requirements for qualification and taxation as a REIT under the Code for its taxable year ending December 31, 2016 2019 and thereafter. All statements regarding the Company’s qualification and taxation as a REIT and descriptions of the Company’s organization and proposed method of operation (inasmuch as they relate to the Company’s qualification and taxation as a REIT) set forth in the Registration Statement, the General Disclosure Package and the Prospectus are correct accurate and fair summaries of the legal or tax matters described therein in all material respects.

Real Estate Investment Trust. The Commencing with the Company’s taxable year ended December 31, 2016, the Company has been been, and upon the sale of the Placement Shares, the Company will continue to be, organized and has operated in conformity with the requirements for qualification and taxation a manner so as to qualify as a real estate investment trust (a “REIT”) under the Section 856 through 860 of Internal Revenue Code of 1986, as amended from time to time (the “Code”), for its taxable years ended December 31, 2010 through December 31, 2015, and the Company’s organization and . The proposed method of operation (of the Company as described in the Registration Statement, the General Disclosure Package Statement and the Prospectus) Prospectus will enable the Company to continue to meet the requirements for qualification and taxation as a REIT under the Code for its taxable year ending December 31, 2016 and thereafterCode. All statements regarding the Company’s qualification and taxation as a REIT and descriptions of the Company’s organization and proposed method of operation set forth in the Registration Statement, the General Disclosure Package Statement and the Prospectus are true, complete and correct in all material respects.

Real Estate Investment Trust. The Company has been organized and has operated in conformity with the requirements for qualification and taxation as a real estate investment trust (a “REIT”) under the Section 856 through 860 of Internal Revenue Code of 1986, as amended from time to time (the “Code”), ) and the Company elected to be taxed as a REIT under the Code effective for its taxable years tax year ended December 31, 2010 through December 31, 2015, and the 2016 upon filing of its federal income tax return for such year. The Company’s organization and method of operation (as described in the Registration Statement, the General Disclosure Package Statement and the Prospectus) Prospectus will enable the Company to continue to meet the requirements for qualification and taxation as a REIT under the Code for its taxable year ending December 31, 2016 2024 and thereafter. All statements regarding the Company’s qualification and taxation as a REIT and descriptions of the Company’s organization and proposed method of operation set forth in the Registration Statement, the General Disclosure Package Statement and the Prospectus are true, complete and correct in all material respects.

Real Estate Investment Trust. The Company has been organized and has operated in conformity with the requirements for qualification and taxation as a real estate investment trust (a “REIT”) under the Internal Revenue Code of 1986, as amended (the “Code”), for its taxable years ended December 31, 2010 2022 through December 31, 20152023, and the Company’s organization and method of operation (as described in the Registration Statement, the General Disclosure Package Statement and the Prospectus) will enable the Company to continue to meet the requirements for qualification and taxation as a REIT under the Code for its taxable year ending December 31, 2016 2024 and thereafter. All statements regarding the Company’s qualification and taxation as a REIT set forth in the Registration Statement, the General Disclosure Package Statement and the Prospectus are correct in all material respects.

Real Estate Investment Trust. The Company has been organized and has operated in conformity with the requirements for qualification and taxation as a real estate investment trust (a “REIT”) under the Internal Revenue Code of 1986, as amended (the “Code”), for its taxable years ended December 31, 2010 through December 31, 201531,2015, and the Company’s organization and method of operation (as described in the Registration Statement, the General Disclosure Package Statement and the Prospectus) will enable the Company to continue to meet the requirements for qualification and taxation as a REIT under the Code for its taxable year ending December 31, 2016 and thereafter. All statements regarding the Company’s qualification and taxation as a REIT set forth in the Registration Statement, the General Disclosure Package Statement and the Prospectus are correct in all material respects.

Real Estate Investment Trust. The Company has been organized and has operated in conformity with the requirements for qualification and taxation as a real estate investment trust (a “REIT”) under the Internal Revenue Code of 1986, as amended (the “Code”), for its taxable years ended December 31, 2010 through December 31, 20152018, and the Company’s organization and method of operation (as described in the Registration Statement, the General Disclosure Package Statement and the Prospectus) will enable the Company to continue to meet the requirements for qualification and taxation as a REIT under the Code for its taxable year ending December 31, 2016 2019 and thereafter. All statements regarding the Company’s qualification and taxation as a REIT set forth in the Registration Statement, the General Disclosure Package Statement and the Prospectus are correct in all material respects.

Real Estate Investment Trust. The Commencing with the Company’s taxable year ended December 31, 2016, the Company has been been, and upon the sale of the Shares, the Company will continue to be, organized and has operated in conformity with the requirements for qualification and taxation a manner so as to qualify as a real estate investment trust (a “REIT”) under the Section 856 through 860 of Internal Revenue Code of 1986, as amended from time to time (the “Code”), for its taxable years ended December 31, 2010 through December 31, 2015, and the Company’s organization and . The proposed method of operation (of the Company as described in the Registration Statement, the General Disclosure Package Statement and the Prospectus) Prospectus will enable the Company to continue to meet the requirements for qualification and taxation as a REIT under the Code for its taxable year ending December 31, 2016 and thereafterCode. All statements regarding the Company’s qualification and taxation as a REIT and descriptions of the Company’s organization and proposed method of operation set forth in the Registration Statement, the General Disclosure Package Statement and the Prospectus are true, complete and correct in all material respects.

Real Estate Investment Trust. The Company has been organized and has operated in conformity with the requirements for qualification and taxation as a real estate investment trust (a “REIT”) under the Internal Revenue Code of 1986, as amended (the “Code”), for its taxable years ended December 31, 2010 through December 31, 20152016, and the Company’s organization and method of operation (as described in the Registration Statement, the General Disclosure Package and the Prospectus) will enable the Company to continue to meet the requirements for qualification and taxation as a REIT under the Code for its taxable year ending December 31, 2016 2017 and thereafter. All statements regarding the Company’s qualification and taxation as a REIT set forth in the Registration Statement, the General Disclosure Package and the Prospectus are correct in all material respects.