That's a good topic.

We've had these discussion before. Much like a REIT, or Unit Investment Trust or a Royalty Trust with a similiar wasting asset (oil in the ground vs Time on the patents), the tax structure is very beneficial. Congress has limited the use of these organizational structures to specific industries, but it seens that due to the primary asset class we've got, we might fit in.

It would require a vote and new Charter/Bylaws, and it would be fought by the BOD because it would end their near planery powers of discretion and control.