IRS Rev. Proc.: REIT, RIC Cash Preservation, Liquidity Safe Harbor Reduced (IRC §301)

Safe harbor provided in Revenue Procedure 2017-45 modified to temporarily reduce the minimum amount of cash that shareholders may receive to not less than 10 percent of the total declared distribution in order for the distribution to be taxable under tax code Section 301, the IRS provided May 4. Revenue Procedure 2017-45 allows a Publicly Offered REIT or Publicly Offered RIC to eliminate C corporation earnings and profits in order to satisfy the REIT or RIC distribution requirements while maintaining sufficient liquidity. That guidance provides for a 20% cash limitation percentage. The guidance applies Solely with ...