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Statement of Additional Info - Gabelli

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nevertheless, would be taxable to the shareholder as ordinary income or capital gain as described above, even though,<br />

from an economic or investment standpoint, it may constitute a partial return <strong>of</strong> capital.<br />

The Funds may invest in stocks <strong>of</strong> foreign companies that are classified under the Code as passive foreign investment<br />

companies ("PFICs"). In general, a foreign company is classified as a PFIC under the Code if at least one-half <strong>of</strong> its<br />

assets constitutes investment-type assets or 75% or more <strong>of</strong> its gross income is investment-type income. Under the PFIC<br />

rules, distribution <strong>of</strong> accumulated earnings or gain from the sale <strong>of</strong> stock <strong>of</strong> the PFIC (referred to as an "excess<br />

distribution") received with respect to PFIC stock is treated as having been realized ratably over the period during which<br />

the Fund held the PFIC stock.<br />

A Fund itself will be subject to tax on the portion, if any, <strong>of</strong> the excess distribution that is allocated to the Fund's holding<br />

period in prior taxable years (and an interest factor will be added to the tax, as if the tax had actually been payable in such<br />

prior taxable years) even though the Fund distributes the corresponding income to shareholders. All excess distributions<br />

are taxable as ordinary income.<br />

A Fund may be able to elect alternative tax treatment with respect to the PFIC stock it holds. One election that is<br />

currently available, provided the appropriate information is received from the PFIC, requires a Fund to generally include<br />

in its gross income its share <strong>of</strong> the earnings <strong>of</strong> a PFIC on a current basis, regardless <strong>of</strong> whether any distributions are<br />

received from the PFIC. If this election is made, the special rules, discussed above, relating to the taxation <strong>of</strong> excess<br />

distributions, would not apply. In addition, other elections may become available that would affect the tax treatment <strong>of</strong><br />

PFIC stock held by a Fund. Each Fund's intention to qualify annually as a regulated investment company may limit its<br />

elections with respect to PFIC stock.<br />

Because the application <strong>of</strong> the PFIC rules may affect, among other things, the character <strong>of</strong> gains, the amount <strong>of</strong> gain or<br />

loss, and the timing <strong>of</strong> the recognition <strong>of</strong> income and loss with respect to PFIC stock, as well as subject a Fund itself to<br />

tax on certain income from PFIC stock, the amount that must be distributed to shareholders by a Fund that holds PFIC<br />

stock, which will be taxed to shareholders as ordinary income or long term capital gain, may be increased or decreased<br />

substantially as compared to a fund that did not invest in PFIC stock. Investors should consult their own tax advisors in<br />

this regard.<br />

Dividends and interest paid by foreign issuers may be subject to withholding and other foreign taxes, which may decrease<br />

the net return on foreign investments as compared to dividends and interest paid by domestic issuers. The Funds do not<br />

expect that they will qualify to elect to pass through to its shareholders the right to take a foreign tax credit for foreign<br />

taxes withheld from dividends and interest payments.<br />

The Funds will be required to report to the Internal Revenue Service all distributions <strong>of</strong> taxable income and capital gains<br />

as well as gross proceeds from the redemption or exchange <strong>of</strong> Fund shares, except in the case <strong>of</strong> exempt shareholders,<br />

which include most corporations. Under the backup withholding provisions, distributions <strong>of</strong> taxable income and capital<br />

gains and proceeds from the redemption or exchange <strong>of</strong> the shares <strong>of</strong> a regulated investment company may be subject to<br />

withholding <strong>of</strong> U.S. federal income tax at the rate <strong>of</strong> 28% in the case <strong>of</strong> non-exempt shareholders who fail to furnish the<br />

Funds with their taxpayer identification numbers and their required certifications regarding their status under the U.S.<br />

federal income tax law. If the withholding provisions are applicable, any such distributions and proceeds, whether taken<br />

in cash or reinvested in additional shares, will be reduced by the amounts required to be withheld. Corporate<br />

shareholders should provide the Funds with their taxpayer identification numbers and should certify their exempt status in<br />

order to avoid possible erroneous application <strong>of</strong> backup withholding. Backup withholding is not an additional tax and<br />

may be credited to a taxpayer’s overall U.S. federal tax liability if the appropriate documentation is provided.<br />

Sale or Redemption <strong>of</strong> Shares<br />

Upon the taxable disposition (including a sale or redemption) <strong>of</strong> shares <strong>of</strong> a Fund, a shareholder may realize a gain or loss<br />

depending upon its basis in the shares. Such gain or loss will be treated as capital gain or loss if the shares are capital<br />

assets in the shareholder’s hands, and will be long term or short term, generally depending upon the shareholder’s holding<br />

period for the shares. Non-corporate shareholders are currently subject to tax at a maximum rate <strong>of</strong> 20% on capital gains<br />

resulting from the disposition <strong>of</strong> shares held for more than twelve months (25% in the case <strong>of</strong> certain capital gains<br />

distributions from REITs subject to depreciation recapture; zero if the taxpayer is, and would be after accounting for such<br />

gains, subject to the tax brackets below 25% for ordinary income). However, a loss realized by a shareholder on the<br />

disposition <strong>of</strong> Fund shares with respect to which capital gains dividends have been paid will, to the extent <strong>of</strong> such capital<br />

69

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