If the taxpayer enjoys a 0% rate, you are correct that this would not necessitate the usage of the QOF step-up. That said, not all taxpayers receive a 0% rate on dividend distributions from a REIT.
Why doesn’t a 0% tax rate on capital gain dividends have the same effect as excluding the gain from gross income when it comes to a QOF REIT?
If the taxpayer enjoys a 0% rate, you are correct that this would not necessitate the usage of the QOF step-up. That said, not all taxpayers receive a 0% rate on dividend distributions from a REIT.
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