Part Cash, Part Stock, 100% Taxable – New IRS Guidance on RIC and REIT Distributions

August 25, 2017

The U.S. Internal Revenue Service (“IRS”), on August 11, 2017, issued Revenue Procedure 2017-45 (the “New Revenue Procedure”). Pursuant to the New Revenue Procedure, the IRS will treat part cash and part stock distributions of regulated investment companies (“RICs”) and real estate investment trusts (“REITs”) as being taxable dividends for all U.S. federal income tax purposes, including for purposes of the RIC and REIT distribution requirements, if the distribution satisfies the requirements of the New Revenue Procedure.

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