The IRS has not issued guidance as to the application of Section 1061 to REIT capital gain dividends. For information purposes only, it is estimated that 3.89% of each distribution identified as capital gain with respect to BPR common and preferred shares in 2018 was derived from certain assets held by BPR and its affiliates for less than 3 years. This issue is complex and there is substantial uncertainty as to the application of the statute. Shareholders should consult with their tax advisors.
This spreadsheet and the accompanying instructions do not constitute, and should not be considered a substitute for, legal advice. The rules governing the proper tax characterization of distributions by REITs can be complex. Each REIT should consult its own tax advisor regarding the proper tax characterization and reporting of the REIT’s distributions.