The company said it filed as Exhibit 99.1 a description of the material U.S. federal income tax considerations relating to its qualification and taxation as a REIT and to the acquisition, ownership and disposition of its stock. The company said the description supersedes prior descriptions to the extent they are inconsistent with it.

8-KOther EventsFiled Feb 22, 2024Period of report Feb 22, 2024Summary published (UTC) Oct 31, 2026

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The company said it filed as Exhibit 99.1 a description of the material U.S. federal income tax considerations relating to its qualification and taxation as a REIT and to the acquisition, ownership and disposition of its stock. The company said the description supersedes prior descriptions to the extent they are inconsistent with it.
The company said it elected to be taxed as a REIT beginning with its 2014 taxable year. Counsel Sullivan & Worcester LLP is of the opinion that the company has qualified as a REIT for its 2014 through 2023 taxable years, subject to assumptions and representations, and that the opinion is not binding on the IRS.
The company said that to maintain its REIT status, at least 75% of its gross income each year must come from real estate-related investments, and at least 95% must come from 75% test-qualifying income and other sources. The company said it has met these tests since 2014 and believes it will continue to meet them.
The company said it must distribute each year at least 90% of its REIT taxable income, among other amounts, to qualify as a REIT, and that a failure to do so could subject it to a 4% nondeductible excise tax. The company also said that if it fails to qualify as a REIT, it would be taxed as a C corporation and would be disqualified from REIT status for the following 4 taxable years.

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Analysis scope · Filing body and confirmed press-release exhibitWe analyzed the filing body and confirmed exhibits. This is not a review of other exhibits, investor presentations or the full earnings call.

Company Files REIT Tax Description, Supersedes Prior Disclosure

The company said it filed as Exhibit 99.1 a description of the material U.S. federal income tax considerations relating to its qualification and taxation as a REIT and to the acquisition, ownership and disposition of its stock. The company said the description supersedes prior descriptions to the extent they are inconsistent with it.

Source · Based on the filing body and exhibits

REIT Election Effective from 2014 Taxable Year and Counsel Opinion

The company said it elected to be taxed as a REIT beginning with its 2014 taxable year. Counsel Sullivan & Worcester LLP is of the opinion that the company has qualified as a REIT for its 2014 through 2023 taxable years, subject to assumptions and representations, and that the opinion is not binding on the IRS.

Source · Based on the filing body and exhibits

REIT Gross Income Tests at 75% and 95% Requirements

The company said that to maintain its REIT status, at least 75% of its gross income each year must come from real estate-related investments, and at least 95% must come from 75% test-qualifying income and other sources. The company said it has met these tests since 2014 and believes it will continue to meet them.

Source · Based on the filing body and exhibits

Distribution Requirements and Tax Consequences of Losing REIT Status

The company said it must distribute each year at least 90% of its REIT taxable income, among other amounts, to qualify as a REIT, and that a failure to do so could subject it to a 4% nondeductible excise tax. The company also said that if it fails to qualify as a REIT, it would be taxed as a C corporation and would be disqualified from REIT status for the following 4 taxable years.

Source · Based on the filing body and exhibits

AI summarized the filing and translated the summary into English; it may differ from the original. For reference only, not investment advice. AI translated the published Korean report into English. Figures are copied as filed, not recalculated.

Original filing

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