Long-term capital gains,
qualified dividend income, ordinary income, and return of capital, if any, will be allocated on a pro-rata basis to all distributions to common shareholders for the year.
This percentage limitation is also applicable to the provision precluding
qualified dividend income treatment to dividend income allocated to investment services partnership interests.
10) Section 1(h)(11) accomplishes this result by taxing
qualified dividend income at the same rate as long-term capital gains.
1(h)(11)(D) and 163(d)(4)(B), taxpayers can elect to include net capital gains and
qualified dividend income in investment income when computing deductible investment interest expense.
1(h) (11)(B)(i),
qualified dividend income consists of dividends received during the tax year from domestic corporations and "qualified foreign corporations" (as defined in Sec.
