The liquidating distribution for USA REIT Fund LLC that was paid on November 1, 2004 of CAD$9.45 per common share and the final liquidating distribution that was paid on May 5, 2005 of CAD$0.029 per common share should both be considered a capital payment for tax purposes. In calculating a gain or loss on the investment investors should subtract their adjusted cost base from the sum of the two payments being $9.479 per common share.
The tax allocation of the distributions paid in 2004 are detailed in the chart below. The return of capital component is a non-taxable amount that serves to reduce the adjusted cost base of the common shares.