putting the "o" in dyor, page-6

a) For tax purposes the amount of income taken up as a dividend received will be the number of shares issued in lieu of the cash dividend x the price per share stated by the BJT to apply to the units issued as payment of the dividend. This is normally a vwap.

b)Assuming the VWAP for distribution purposes is 40 cents the answer is yes, however you will still have a tax liability to pay when the distribution is taken up in your tax return.