Article 11 of the Finance Law for 2003, codified under Article 208-C of the French Tax Code (FTC), provides for a new tax regime to the benefit of real estate companies which are listed on a French stock exchange. This tax regime (the SIIC Regime) exempts from French corporate income tax, subject to certain distribution requirements, rental income earned by such companies as well as capital gains that they realize on the sale of real estate assets, shares in real estate partnerships which are tr