Excise tax on undistributed income of real estate investment trusts

There is hereby imposed a tax on every real estate investment trust for each calendar year equal to 4 percent of the excess (if any) of— For purposes of this section— The term “required distribution” means, with respect to any calendar year, the sum of— The amount determined under paragraph (1) for any calendar year shall be increased by the excess (if any) of— The grossed up required distribution for any calendar year is the required distribution for such year determined— For purposes of this section— The term “distributed amount” means, with respect to any calendar year, the sum of— The amount determined under paragraph (1) for any calendar year shall be increased by the excess (if any) of— The amount of the dividends paid during any calendar year shall be determined without regard to the provisions of section 858. The tax imposed by this section for any calendar year shall be paid on or before March 15 of the following calendar year. For purposes of this section— The term “ordinary income” means the real estate investment trust taxable income (as defined in section 857(b)(2)) determined— The term “capital gain net income” has the meaning given such term by section 1222(9) (determined by treating the calendar year as the trust’s taxable year). The amount determined under subparagraph (A) shall be reduced by the amount of the trust’s net ordinary loss for the taxable year. For purposes of this paragraph, the net ordinary loss for the calendar year is the amount which would be net operating loss of the trust for the calendar year if the amount of such loss were determined in the same manner as ordinary income is determined under paragraph (1). In the case of any deficiency dividend (as defined in section 860(f))—