The Service will not challenge the qualification of property as either «replacement property» or «relinquished property» (as defined in Section 1.1031 (k)-1 (a)-RRB- for purposes of Section 1031 and the regulations thereunder, or the treatment of the exchange accommodation titleholder as the beneficial owner of such
property for federal income tax purposes, if the property is held in a QEAA.
The potential tax benefits from investing in MLPs depend on their being treated as
partnerships for federal income tax purposes and, if the MLP is deemed to be a corporation, then its income would be subject to federal taxation at the entity level, reducing the amount of cash available for distribution to the fund which could result in a reduction of the fund's value.
Personal household effects, registered aircraft, licensed vehicles, certain personal property warehoused in the state, and business personal property that is not
depreciated for federal income tax purposes are exempt from the tax.
A conversion from Investor Class shares to Institutional Class shares of the Fund or from Institutional Class shares to Investor Class shares of the Fund pursuant to the preceding paragraphs should generally not be a taxable
exchange for federal income tax purposes.
Distributions may include amounts
characterized for federal income tax purposes as ordinary dividends (including qualified dividends), capital gain distributions and nondividend distributions, also known as return of capital distributions.
Interest earned on EE bonds with January 1, 1990, and later issue dates may qualify for exclusion from income
for Federal income tax purposes if the owner pays his or her tuition and required fees or those of his or her spouse or legally dependent children at colleges, universities, and qualified technical schools during the year eligible bonds are redeemed.
Each individual that co-invests in or through a Delaware Statutory trust or DST is a beneficiary of the Delaware Statutory Trust and therefore owns a «beneficial interest» in the
DST for Federal income tax purposes.
This procedure provides a safe harbor under which the Service will not challenge (a) the qualification of property as either «replacement property» or «relinquished property» for purposes of section 1031 of the Code or (b) the treatment of the» «exchange accommodation titleholder» as the beneficial owner of such
property for federal income tax purposes, if the property is held in a «qualified exchange accommodation arrangement» (QEAA).
Municipal bonds may be obligations of a variety of issuers including governmental entities or other qualifying issuers, the payments from which, in the opinion of bond counsel to the issuer, are excludable from gross
income for Federal income tax purposes.