RIC’s Dividend Designations May Exceed Dividend Distributions | Also Subsidiary REITs May Use Non-U.S. Dollar Functional Currency
Author: Staff Editors.
Source: Volume 19, Number 02, November/December 2005 , pp.35-38(4)
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Abstract:
In Rev. Rul. 2005-31, the IRS determined that for the dividend designations permitted in three sections, with two subsections in each section, a regulated investment company may designate the maximum amount permitted under each provision even if the aggregate of these amounts exceeds the total amount of the RIC’s total dividend distributions. The sections involved are 852(b)(3)(C) and (b)(5)(A), 854(b)(1) and (2), and 871(k)(1)(C) and (2)(C). Secondly, the ruling held that individual shareholders of the RIC who are U.S. persons may apply designations to the dividends they receive from the RIC that differ from designations applied by shareholders who are nonresident alien individuals. In a separate release, PLR 200519007, subsidiary real estate investment trusts (REITs) were permitted to use a currency other than the U.S. dollar as their functional currency.Keywords:
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