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In December 2008, the Internal Revenue Service (the "IRS") issued Revenue Procedure 2008-68, providing temporary guidance regarding certain stock distributions by publicly traded real estate investment trusts ("REITs").  The taxpayer-favorable guidance gave publicly traded REITs greater flexibility to satisfy their tax-related distribution requirements while conserving cash in an illiquid market.  On January 7, 2009, the IRS issued Revenue Procedure 2009-15 (the "Procedure"), extending its prior guidance to publicly traded regulated investment companies ("RICs"). ...

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