Throughout the year, Owl Rock Capital Corporation (the “Company”) generates qualified interest income (“QII”) that may be exempt from U.S. withholding tax when distributed to non-U.S. stockholders. The Company is a regulated investment company (“RIC”) and is permitted to designate the portion of distributions that represent qualified interest income, net of deductions properly allocable to such income, as an “interest-related dividend” that is generally exempt from U.S. withholding tax when paid to non-U.S. stockholders in accordance with Subchapter M of the Internal Revenue Code of 1986, as amended (“IRC”).
The current year’s QII information is estimated based on the Company’s activity to-date. The tax status of distributions for a tax year depends on the Company’s total amount of taxable income for the year, therefore, the tax status cannot be confirmed until after the end of the tax year. Accordingly, the Company’s distributions for the tax year may be recharacterized later based upon subsequent events.
As applicable, the Company reports the final tax character of its distributions for U.S. federal income tax purposes annually to stockholders on Internal Revenue Service Form 1099-DIV issued after the end of the year. The Company’s Form 10-Ks also include information regarding the Company’s distributions for each fiscal year and historical 10-K filings can be viewed here. Because each stockholder’s tax status is unique, stockholders should consult their tax advisor regarding the appropriate tax treatment of this information.
For U.S. shareholders, the Company’s distributions are generally not “qualified dividends” for tax purposes. As a RIC, the Company does not typically pay U.S. federal income taxes on ordinary income or capital gains passed through to shareholders as dividends. As a result, the majority of the distributions received by shareholders are taxable as ordinary income and a portion may qualify as long-term capital gains.
This is general information. It is not intended to constitute tax, legal, investment, or other professional advice and should not be relied upon for tax advice purposes. Stockholders should consult their tax advisor for tax guidance pertinent to specific facts and circumstances.
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