Excluding a handful of exceptions, CEFs themselves do not pay taxes. Instead, like open-end mutual funds and ETFs, CEFs pass the tax consequences of their investments onto their shareholders. To maintain tax-free status, a CEF must pass on to shareholders, generally speaking, roughly:
- 90% or more of net investment income from dividends and interest payments
- 98% or more of net realized capital gains
Investors should be aware of the source of their distributions. CEF distributions have 4 potential sources:
- Interest payments on fixed-income portfolio holdings
- Dividends from equity holdings
- Realized capital gains
- Return of capital:
- Pass-through (from master limited partnership investments, primarily)
- Constructive (from unrealized capital gains)
- Destructive (investors are literally receiving their own capital, minus expenses)
For accounting and tax purposes, distributions must be linked back to the initial source: usually dividends, income, and/or realized capital gains. These are actual cash inflows into the fund. When the distribution exceeds the cash generated from these sources, the fund must ascribe the initial source as a return of capital. Throughout the calendar year, funds estimate the breakdown of their distributions. Shareholders receive a Form 1099-DIV in January with the actual distribution breakdown for the prior year for tax purposes. Any previous information regarding the categorization of distributions are only estimates.
Prospective investors are at a disadvantage because they do not have access to the tax forms. They must wait until the fund files its annual statement to see the finalized distribution breakdowns in order to discern its use (if any) of return of capital. Fidelity.com displays a fund's most recent distributions, along with its sources, as well as distributions for 9 quarters.
Imprecise language obfuscates the source of distributions. Just as one wouldn't say a bond pays a dividend or a stock pays a coupon, investors shouldn't say that CEFs have a yield or pay a dividend.
Referring to distributions as "yield":
- Comes from a fixed-income investing mindset
- Successful CEF investors have a CEF mindset
- Ignores the potential other sources of the distribution
- Is only correct when a fixed-income portfolio distributes nothing other than the interest payments it receives on its portfolio holdings or when referring to a dividend yield, as mentioned next
Referring to distributions as "dividends":
- Comes from an equity investing mindset
- Does not acknowledge the other sources of the distribution
- Is only correct when an equity portfolio distributes nothing other than the dividends it receives on its portfolio holdings; it's rarely correct to refer to an equity CEF's "dividend" payment, as equity CEFs typically also distribute capital gains
An easy way to separate a CEF amateur from a CEF professional is to listen to whether they refer to "yield," "dividends," or "distribution rate."
Why it's important to understand the source of distributions and use precise language
First are the tax implications: Net investment income, capital gains, and return of capital are treated far differently under the US tax code. Secondly, the source of the distribution is important in understanding the likely sustainability of that distribution:
- Distributions primarily from net investment income are considered relatively safe
- Distributions from capital gains are considered suspect, as there is no guarantee that the portfolio can generate such capital gains in the future
- This same reasoning also makes distributions from constructive return of capital suspect
- Distributions from destructive return of capital are not only economically bogus, but if they are consistently used, they are also predictive of future distribution reductions
CEFs have distributions, not yields or dividends:
- A CEF portfolio's yield may contribute to the distribution
- Dividends received in the CEF portfolio may contribute to the distribution
It is important that investors understand the source of their CEF's distribution. Many unwitting investors pay extreme premium prices for CEFs that have large distribution rates derived almost solely from destructive return of capital.