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Badger Daylighting Ltd. Releases United States Tax Information for Badger Income Fund 2010 Distributions
Feb. 24, 2011 (Filing Services Canada) -- Badger Daylighting Ltd. (BAD - TSX), On December 31, ...
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[{"type":"text","content":"\nBadger Daylighting Ltd. Releases United States Tax Information for Badger Income Fund 2010 Distributions\n\n Feb. 24, 2011 (Filing Services Canada) -- Badger Daylighting Ltd. (BAD - TSX), On December 31, 2010 Badger Income Fund was reorganized into a corporation called Badger Daylighting Ltd. (\"Badger\"). The following reporting is for Badger Income Fund. The following information is being provided to assist individual U.S. holders of fund units of Badger Income Fund who hold their units through a broker or other intermediary in reporting dividends received from Badger Income Fund on their IRS Form 1040 - U.S. Individual Income Tax Return for the calendar year 2010.  The information is intended as a general guideline and should not be considered legal advice to any particular existing or potential holder of fund units.  The information is not intended to cover all possible U.S. income tax considerations.  Holders or potential holders of fund units of Badger Income Fund should consult their own legal and tax advisors as to specific U.S. tax consequences of holding the fund units of Badger Income Fund.We believe for U.S. federal income tax purposes, that the units of Badger Income Fund are more likely than not treated as equity in a corporation, rather than as debt, and that distributions paid to its individual U.S. unitholders will more likely than not be taxable dividends provided they do not represent a return of capital.  The portion of the trust distributions that is considered a dividend for U.S. income tax purposes is determined based upon the greater of Badger Income Fund's current or accumulated earnings and profits (\"E&P\") as determined in accordance with U.S. income tax principals.  With respect to cash distributions declared in 2010 to U.S. individual unitholders, 100 percent should be reported as taxable dividends.As the Badger Income Fund is a qualified foreign corporation the portion of the distributions made during 2010 that are considered to be dividends should be 'qualifying dividends' and therefore be eligible for the reduced rate of tax applicable to net capital gains.  Badger Income Fund is not required to issue Form 1099 DIV's; however, U.S. unitholders may receive a Form 1099 DIV from a broker or intermediary that may not reflect the dividend a...