A distribution on our Class A or Class B common shares will be treated for federal income tax purposes as a distribution received by the Participant notwithstanding that it is used to purchase additional Class B common shares pursuant to the Plan. The fair market value of our Class B common shares acquired with cash distributions reinvested under the Plan will represent dividend income to a Participant to the extent of the Participant’s share of our current or accumulated earnings and profits, with any excess being treated first as a tax-free return of capital to the extent of the Participant’s tax basis in its shares, and then as a gain from the sale or exchange of the Participant’s shares. In addition, the amount of any brokerage fees, commissions, and service charges incurred by us on behalf of a Participant whose distributions are reinvested to purchase shares on the open market may also constitute a dividend to such Participant for federal income tax purposes to the extent described above. Although the matter is not free from doubt, we intend to take the position that costs of administering the Plan that are paid by us do not constitute a distribution to the Participants for federal income tax purposes.

Distributions paid to corporate shareholders, including amounts taxable as dividends to corporate participants as described above, will not be eligible for the corporate dividends-received deduction for federal income tax purposes.

A Participant’s tax basis in additional Class B common shares acquired under the Plan with reinvested distributions will be equal to the amount deemed reinvested, including the amount of any brokerage fees, commissions and service charges, if any, paid on behalf of such Participant and treated as a distribution to such Participant, divided by the number of our Class B common shares issued to the Participant under the Plan at such time. The Participant’s holding period for such shares will commence on the day after the investment date.

A Participant will recognize gain or loss when a fractional share interest is liquidated or when the Participant sells or exchanges shares received from the Plan. Such gain or loss will equal the difference between the amount which the Participant receives for such fractional share interest or such shares and the tax basis therefore.

In the case of Participants whose distributions are subject to withholding of federal income tax, the amount reinvested will be reduced by the amount of tax required to be withheld.


If you would like to have your dividend check automatically deposited into your bank account, please contact our transfer agent, American Stock Transfer & Trust Company, LLC, at 1-800-937-5449.