The Fund believes that, for U.S. federal income tax purposes, the shares of the Fund will more likely than not be properly classified as equity in a corporation rather than as debt, and that dividends paid to its individual U.S. shareholders should therefore be treated as qualified dividends. As such, the distributions made during 2010, considered dividends, should qualify for the reduced rate of tax applicable to certain capital gains.
With respect to cash distributions paid in 2010 to U.S. individual shareholders, 48.96 percent should be reported as a non-taxable return of capital and 51.04 percent should be reported as qualified dividends.
The Fund is not required to issue Form 1099-DIV’s. U.S. shareholders may have already received this Form from a broker or intermediary with incorrect information. Consequently, U.S. shareholders should consult their brokers and tax advisors to ensure that this information is correctly reflected on their tax returns. Brokers and intermediaries may or may not be required to issue amended Form 1099-DIV’s.