They will sometimes puts out deep discount tender offers right after a non-traded program suspends its stock repurchase program. Basically they buy non-traded retail programs at steep discounts via tender offers and then either hold them through liquidation, or sell them at a higher price on auction sites. Mackenzie Sponsors/advises non-traded funds that specialize in exploiting inefficiencies in the market for illiquid retail programs. Īnyways, Mackenzie Capital’s group of funds are fascinating on many levels. We qualified to be taxed as a REIT beginning with the tax year ended December 31, 2014, and made our REIT election in our 2014 tax return. MRC was formed with the intention of qualifying to be taxed as a real estate investment trust (“REIT”) as defined under Subchapter M of the Internal Revenue Code of 1986, as amended (the “Code”). MacKenzie Capital Management, LP (“ MacKenzie “) provides us with non-investment management services and administrative services necessary for us to operate. We are advised by MCM Advisers, LP (“ the Adviser ” or “ MCM Advisers “). Our investment objective is to generate both current income and capital appreciation through investments in real estate companies (as defined below). (“ MRC ,” “ we ” or “ us “) is an externally managed non-diversified company that has elected to be treated as a business development company (“ BDC “) under the Investment Company Act of 1940 (the “ 1940 Act “). Mackenzie Realty Capital is a BDC that is also a REIT under the tax code. These categories are not mutually exclusive. However, investment limitations are different.īDC is an SEC construct. RICs and REITs have very similar requirements in terms of distributing income, and nearly identical benefits in terms of avoiding corporate level taxation. REITs qualify as REITs under the tax code. BDCs by tradition also happen to usually be RICs under the tax code.
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