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The Canadian government in its infinite wisdom is proposing to tax non-resident trusts and foreign investment entities (FIE) on the basis of their year-end value. This means that unrealized gains on these investments would be subject to taxation. However, it is proposed that interests in United States investment funds that are considered "regulated investment companies" (RICs) for the purposes of the U.S. Internal Revenue Code be excluded from the application of the FIE rules. To qualify as a RIC, an investment fund must annually distribute 90 per cent or more of its income to its unitholders. The goverment has specified that a number of U.S. funds including DIAMONDS, SPDRs and QQQs are RICs. In their proposal no mention is made of REITs one way or the other.

My question is whether REITS are considered "regulated investment companies" (RICs) for the purposes of the U.S. Internal Revenue Code
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