While both CCA and GEO have positioned themselves for conversion to REIT structures, neither company has received approval from the IRS despite their requests for a privateletterruling (PLR) regarding their REIT intentions.
Because the only way the public is likely to find out about a privateletterruling request is if the taxpayer behind the request announces it, it is quite possible that there are other requests in process.
The IRS did not issue a privateletterruling to the NASD concerning the payment to members until March 13, 2007, nearly four months after the proxy was issued and nearly two months after the voting had closed.
When I wrote the article, I knew there were rumors that a revenue ruling might be requested soon, but not if any taxpayers had yet requested privateletter rulings.