The relatively new Qualified Dividend tax law (5 to 15% rate if
you hold stock for 61 of 120 day period that wraps the ex-div date)
has some exceptions for what I call "weird" stocks:
- foreign stocks
- companies whose dividends smell like Interest 

I have some specific examples which I would like to ask
whether or not they qualify for the lower rates:

Example 1: TSP - Telecom de São Paulo, aka TELESP
Brazilian telecomm company with a massive dividend.
A pure foreign stock with no US operations whatsoever.

Example 2: ABN - ABN AMRO
Dutch bank with large U.S. operations and presence.

Example 3: RAS - RAIT Investment Trust
Hedged portfolio of mortgage loans. Elected to be treated as
a REIT and is listed in etfconnect.com

Example 4: IMH - Impac Mortgage Holdings
Another hedged portfolio of mortgage loans, except they did
not elect to be treated as a REIT.

Example 5: EOP - Equity Office Property
A more traditional REIT... they own buildings instead of loans. 

So, which of the above can be eligible for "Qualified Dividend"
treatment?

Thanks.

---

Clarification of Question by atr-ga on 01 Nov 2005 06:04 PST

I found the answer on foreign stocks. NYSE-listed ADRs automatically
qualify. Still unclear on REITs, especially mortgage-holding REITs,
since it might appear that those are a pass-through for interest income. 

http://www.irs.gov/businesses/small/article/0,,id=122523,00.html

Qualified foreign corporation

A foreign corporation is a qualified foreign corporation if it meets
any of the following conditions.

The corporation is incorporated in a U.S. possession. 
The corporation is eligible for the benefits of a comprehensive income
tax treaty with the United States that the Treasury Department
determines is satisfactory for this purpose and that includes an
exchange of information program. For a list of those treaties, see
Table 9 ?1 (Publication 17, page 70).
The corporation does not meet (1) or (2) above, but the stock for
which the dividend is paid is common or ordinary stock, or an American
depository receipt in respect of that stock, which is listed on one of
the following markets:


The New York Stock Exchange, 
The NASDAQ Stock Market, 
The American Stock Exchange, 
The Boston Stock Exchange, 
The Cincinnati Stock Exchange, 
The Chicago Stock Exchange, 
The Philadelphia Stock Exchange or, 
The Pacific Exchange.