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The Senate Report explained that the 5% Exception was meant to remove “from treatment as effectively connected income for a foreign investor a capital gain distribution from a REIT” and justified it as a means to “provide greater conformity in the tax consequences of REIT distributions and other corporate stock distributions.” The use of the language “capital gain distribution from a REIT” would suggest that the Senate Report was referring to capital gains dividends, rather than liquidating distributions and that the distributions to which the 5% Exception (and, thus, Code Sec.

857(b)(3)(F), enacted at the same time as the 5% Exception, which recasts distributions subject to the 5% Exception as ordinary dividends, applies only to the amount which would be considered capital gain dividends (and not liquidating distributions).

I need to do the updating operation on what row is clicked." Select Command="SELECT a.tenantcode, a.name, a.fixedrate, a.percentrate, a.percentage, b.locationd, c.status FROM TENANTNEW AS a INNER JOIN LOCATION AS b ON a.

This could result in exceptions being swallowed (even though they are logged) and then the program can continue in an unknown state.

857(b)(3)(C), a REIT is permitted to designate as “capital gain dividends” its regular dividends, up to the amount of its “net capital gain” for the year.

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