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Hello Kaja Bear N,
How did you come up with your buy and sell settings on the MACD indicator? Do you optimize or is there a standard setting for different asset classes?
swing man,
I'm looking for a move to 38 then downhill from there. Max pain plus significant resistence appears to be at 38. My current target is 37.32 on the first down wave.
I currently use the MACD with the standard settings. Does anyone here use different settings for either the buy or sell signals?
Thanks FA...
FA,
Do you use different settings for your MACD analysis of buy and sell signals? If so, what settings do you use for each? I've been using the defaults of 12, 26, 9 but I'm interested in using a customized set for buy/sell analysis.
BULLarkey,
Thanks for the info as it is timely.
W@G2~QQQQ 06/22/05 for a 06/24/05 close~
37.32 frenchee
Thanks sir...
Thanks for the alert OFC!
Bliss,
Thanks for the link to Amanita Newsletter Subscriptions.
Hi Gizmo,
Wondering if you use different parameters on your MACD buy and sell signals. If so, what settings do you find most useful for the buy and sell signals? Lastly, are the settings useful across all securities or are they specific to a security class?
Thanks sir...
Gizmo,
The S&P500 COT report looks quite interesting...
Thanks for the link...
Gizmo,
I think the market has already factored oil in the 50s. But I don't think oil in the 60s is discounted in. Most pundits were calling for oil in the 40s this summer. I don't think we will see that.
Get your SPY shorts ready when oil hits 60.
Didn't get in last Friday. I didn't like the configuration of the CMF indicator and Chaikin Oscillator. Unless decisive volume comes back, I'll not go long. Perhaps a new short is in order?
Way to go DrWorm...
W@G1~QQQQ 06/20/05 for a 06/22/05 close
37.32 frenchee
That's one of the attributes of a strong-trending security...
Thanks Bliss...
Hello Swing Man,
Tea leaves are pointing to higher prices. CFI and Slow Stochastics when on a buy today and I closed my QQQQ short.
I'm flat now but looking to go long. 38.07 or higher on Friday gets me in as that's is the current Parabolic SAR point to go long. I'd like to see more volume...
Hi Bliss,
Is it still melt-up time for VXF too?
Great!
With $rut ADX increasing should be more gains ahead. MACD and Parabolic SAR point full-speed ahead too. I'm thinking a retracement will only pull back between the 5 and 21-day SMA. I'd be buying on dips to these areas.
FA,
What's your current analysis of TLT?
Thanks.
congrats rayrohn
W@G2~QQQQ 06/15/05 for a 06/17/05 close
37.23 patchdodd
37.02 frenchee
Dr Worm,
I'm looking for a bounce around 92.44-92.61. TLT not yet oversold but should get a bounce this week.
negative for me
Here's some info about the Aroon
Developed by Tushar Chande in 1995, Aroon is an indicator system that can be used to determine whether a stock is trending or not and how strong the trend is. "Aroon" means "Dawn's Early Light" in Sanskrit and Chande choose that name for this indicator since it is designed to reveal the beginning of a new trend.
The Aroon indicator system consists of two lines, 'Aroon(up)' and 'Aroon(down)'. It takes a single parameter which is the number of time periods to use in the calculation. Aroon(up) is the amount of time (on a percentage basis) that has elapsed between the start of the time period and the point at which the highest price during that time period occurred. If the stock closes at a new high for the given period, Aroon(up) will be +100. For each subsequent period that passes without another new high, Aroon(up) moves down by an amount equal to (1 / # of periods) x 100.
Technically, the formula for Aroon(up) is:
[ [ (# of periods) - (# of periods since highest high during that time) ] / (# of periods) ] x 100
For example, consider plotting a 10-period Aroon(up) line on a daily chart. If the highest price for the past ten days occurred 6 days ago (4 days since the start of the time period), Aroon(up) for today would be equal to ((10-6)/10) x 100 = 40.
Aroon(down) is calculated in just the opposite manner, looking for new lows instead of new highs. When a new low is set, Aroon(down) is equal to +100. For each subsequent period that passes without another new low, Aroon(down) moves down by an amount equal to (1 / # of periods) x 100.
The formula for Aroon(down) is :
[ [ (# of periods) - (# of periods since lowest low during that time) ] / (# of periods) ] x 100
Continuing the example above, if the lowest price in that same ten-day period happened yesterday (i.e. on day 9), Aroon(down) for today would be 90.
Aroon Oscillator
A separate indicator called the Aroon Oscillator can be constructed by subtracting Aroon(down) from Aroon(up). Since Aroon(up) and Aroon(down) oscillate between 0 and +100, the Aroon Oscillator oscillate between -100 and +100 with zero as the center crossover line.
Interpretation Guidelines
Chande states that when Aroon(up) and Aroon(down) are moving lower in close proximity, it signals that a consolidation phase is under way and no strong trend is evident. When Aroon(up) dips below 50, it indicates that the current trend has lost its upwards momentum. Similarly, when Aroon(down) dips below 50, the current downtrend has lost its momentum. Values above 70 indicate a strong trend in the same direction as the Aroon (up or down) is under way.
The Aroon Oscillator signals an upward trend is underway when it is above zero and a downward trend is underway when it falls below zero. The farther away the oscillator is from the zero line, the stronger the trend.
In some ways, Aroon is similar to Wilder's DMI system (and the Aroon Oscillator is similar to Wilder's ADX line) however the Aroon is constructed in a completely different manner. Divergences between the two systems may be very instructive.
you da man!
Here's an interview you will probably like then...
Hi, my name is Dave Goodboy. I'm Executive Producer of RealWorldTrading.com, and today I'm pleased to be joined by world-renowned financial astrologer Arch Crawford (www.crawfordperspectives.com). I fully realize that this is a highly controversial and unusual subject, however, Arch has one of the best documented historic records for correct market calls of any market analyst. In fact, over the last 3 and 6 month time frames,Timer Digest, has ranked him #3 of all market letter writers. Jump on board for a journey into this esoteric subject!
Dave: How are you today, Arch?
Arch: Very well, thank you.
Dave: Let's start at the beginning. What first got you interested in the financial markets?
Arch: I always loved numbers as a child and used to extract square roots for fun and I saw my Father looking in the paper and there's this whole page of numbers. I loved the numbers so I started watching the stock market, pulling out stocks under $10 through the A's, B's and halfway through through the C's--and there were a lot of them in 1954. The methods I studied were basically technical. In 1960, I kept a chart of US Steel --there was a big steel strike--and I kept the headlines on the chart. And it made no sense whatsoever.
Dave: There was no correlation between the headline and the stock movement?
Arch: Exactly. One of the first books I read was Darvas' How I Made $2 Million In The Stock Market. He was a dancer and he used a simple trend-following method. A couple of years later I went to work for Merrill Lynch in Raleigh N.C., putting up prices on a chalkboard and 2-3 months after that they got an electronic board and I became an assistant in the cage.
Dave: This is the early '60s?
Arch: Yes, this is 1961. I had been studying math and physics at the University of North Carolina and I started off with really great grades and they were beginning to drift lower and lower and I figured I would go do what I wanted to do before I got thrown out, so I left while I still had decent grades. I told Merrill Lynch "This is what I want to do with my life, send me to New York" and they said,"don't be ridiculous." So later, after I'd been there a while I said I quit, I'm going to New York and look for a job. They said "Don't do that, we'll transfer you." They said "What department would you like?" and I told them technical research. They sent me right up to the research department but the technical things I was doing at that time was I was actually drawing the weekly charts of Merrill Lynch's industry specialists and that took me three days to do 45 charts. While I was in Raleigh the commodity guy there got me Edwards & McGee and they were getting the trendline charts from Commodity Research Bureau and it had 600 charts every week. I use to draw all the lines and supports and resistance and trendlines and look at the moving averages and make a projection as to what was going to happen and go back and look at last week's while I'm doing this week's and see what worked out and what didn't. I'm self-taught from that standpoint, using Edwards & McGee. I was spending every night in the library. I made friends with the librarian--an elderly Irish lady--and I bought lottery tickets from her, so she let me stay in the library at night and lock it up at 12:00. I was looking at the chart of the market and it was beginning to form a multiple head and shoulder top pattern.
Dave: When you say the market, you mean the Dow?
Arch: The Dow Jones, yes. I said if this pattern remains symmetrical, the market will top in the middle of December and it will crash next year in 1962. It topped in the middle of December. It finished the head and shoulder top and broke down on April 13, the day Kennedy made the steel companies roll back the price increases. That broke the neckline and it started down and then it drifted down and rallied a bit and drifted down and rallied a bit and then started turning very nasty and we went into the crash of '62. And I was going around saying "it's going to crash" and I got the nickname "Crash Crawford." And then it actually did it--the worst crash since 1929.
Dave: That was your first major accurate prediction?
Arch: Yes. I also turned 21 in the meantime on April 17th and inherited $1000 from a sweet aunt who had died and I put it all in puts and made seven times my money, so that was my beginning.
Dave: How did you go from being a technical analyst to a financial astrologer?
Arch: On the day before my birthday, in 1963, the Wall Street Journal had a front-page article about three guys who were predicting the market using astrology. The credible one was Lt. Cmdr. David Williams who had been head of the purchasing department for Con Ed for 40 years and a Lt Cmdr in the Navy in the Big War and he was a fine gentleman. Williams had written a pamphlet called Astro-economics in 1955. I went out and bought it. Next to that pamphlet in this metaphysical bookstore was Donald Bradley's Stock Market Prediction and he had developed a model using all two-planet pairs. I started keeping his model by hand and--thank God for computers! It was a lot of calculation but it was worth it. The market would follow that line for several months and then if would go off and do something else and for several months it would be off of that line and then it would come back onto it sometime later.
Dave: What particular planets?
Arch: All of them. Ten counting the Sun and moon. The Moon didn't count in them because it was too quick. What I found in following that for a while was that when there is a large configuration involving several planets it becomes what the Mandelbrot set, the chaos people, call a "strange attractor" which would take the market up or down to the date of this large configuration was most exact or to the last aspect between whatever planets were involved and then the market would turn and go the other way.
Dave: When you say configuration, what do you mean?
Arch: A number of planets in harmonic relationship. A harmonic relationship of one means two planets have the same longitude in space.
Dave: They're in line with each other
Arch: Yes. Looking out from Earth, they're in the same place. A harmonic of two is like a full Moon where one is opposite the other separating the sky into two different parts, the left half and the right half. The second harmonic is 180 degrees, which is one-half of the 360 degree circle, and the third harmonic is 120 degrees which is one-third of the 260 degree circle. So a trine is 120 degrees and a square is 90 degrees. These are the ones most traditional astrologers use.
Dave: You noticed that these configurations would affect the market,am I following you?
Arch: Oh absolutely. When several planets are involved instead of just these two-planet pairs, it becomes a unique event and that's what makes it a strange attractor and the market will pull up to that day and then down or down to that day and then up.
Dave: How many times a month do these strange attractors occur?
Arch: Two to three times a year on a good year. Other than that they follow the Bradley somewhat.
Dave: You found David Williams' pamphlet and the Bradley book...
Arch: First I got a book of planetary positions and I noticed when they were in the one-third and one-sixth harmonic harmonic the market tended to go up and when they were in the second and fourth harmonic it tended to go down. That's what I entered into my notes and that's what Williams said in his book. In terms of statistics there are so many factors involved that a lot of scientists can look at this and they will say "Ahh, there are not statistically meaningful" but you can combine them in two or three or four cycles together and they become extremely meaningful.
Dave: These strange attractors that occur two to three times per year... is it something that changes the trend of the market?
Arch: Yes. It'll either take them up to that day and drop it or down to that day and rally it.
Dave: This really sounds crazy. What's the theory behind the concept? Why does it seem to work?
Arch: You got me. The closest I know about was from another guy named John Nelson, who was a radio propagation specialist for RCA Corporation, and they put him on the top of a building with a telescope and said "figure out when the darn sunspots are going to blow up" because before the days of the satellites they were sending dataflow across the North Atlantic. When the sunspots hit they had to switch to sending to South America and then over to Africa and then back up to Europe and it was time consuming and costly so they wanted to know when these things were going to happen. Nelson by regular cyclical means got up to a 65% accuracy rate which was not satisfactory at all and someone said "why dont you look at the planetary alignment around the sun at the times of these sunspots because that may give you a handle on what you want to look at." So he took the 13 worst magnetic storms on the Earth that were on record with RCA and drew the horoscope heliocentric chart--heliocentric meaning the Sun in the middle. He was totally blown away by all the harmonic ratios in the days that these sunspots popped off in a big way.
Dave: So it's basically somehow affecting the magnetic field which in turn is affecting people's behavior?
Arch: Yes. Nelson and I figured that if there is a powerful alignment heliocentrically they'll blow the sunspots out and if it happens to be a high tidal force--a new Moon or full Moon--then the ionized layer of the Earth's atmosphere will be brought down close to the Earth and make people crazy.
Dave: Let me see if I follow you. It affects people's emotions--making them feel elated--therefore they will buy stocks, and when they're depressed hit they will sell stocks?
Arch:When the electrons hit it tends to be depressive and when the protons hit hit it tends to be elating and so if you get a major solar flare it tends to throw a lot of heavy protons but the electrons get there first so the first couple of days the market drops and then when the protons get there it goes screaming the heck up. But there are a lot of complications with that. In the 1987 crash, there were the largest number of electrons hitting the atmosphere that I had ever seen for the longest period of time. When the electrons got over 1 to the third per cubic centimeter, that's when the market started coming apart. It proceeded on down on Friday--of course that was options expiration--and crashed on more Monday. The strategy at that time was if the market went down a certain amount you sell S&P futures are you are protected to whatever level. The system they had would protect you down to five standard deviations from normal. Monday, it was a seven standard deviation event and the whole system was threatening to come down.
Dave: What happened the day after that?
Arch: The next morning it was down like another 200 points in 15 minutes with hardly any stocks open. The Fed said "anybody comes in from Wall Street that wants money, give it to them" and the market came roaring back and was positive by 10:00.
Dave: Let's talk about another astrological event--the eclipse. Are there any correlations between market movements and eclipses?
Arch: Yes. They are the most powerful events, taken individually. W.D. Gann wrote seven books about the market and he was an astrologer but he rarely said anything specifically about astrology in all of those books.
Dave: He was very vague in everything he wrote.
Arch: Well he was very secretive about it and swore the people around him to secrecy relative to astrology. David Williams actually introduced me to a friend of his who had worked for Gann and he said "Yeah he swore us to secrecy but we didn't know anything anyway." (laughs)
Dave: What happens during a solar eclipse?
Arch: The solar eclipse tends to have a longer-term effect, not necessarily so much on the day it happens--in other words it will be a more important event, but the lunar eclipse tends to be more dramatic for one day or two days.
Dave: How many eclipses are there per year?
Arch: There are 3-5 eclipses per year. Around the time of the 1987 crash, The Wall Street Journal ran an article about a guy who had come up with a Mayan calendar date that was very important, and that was supposed to be August 17 and all the new new age people were going to sacred sites and dancing and drumming and praying and meditating and doing what they do. It was called the "Harmonic Convergence." It was supposed to be this Mayan date. Well I looked at this date and I didn't see anything. I looked forward and here seven days later was the tightest 5-body conjunction in at least 800 years and they were all visible bodies. And I said "that is what the Mayans were talking about." I said "this market will peak on August 24, give or take three days, after which we will have a horrendous crash." The market peaked at Noon on August 25 and it dropped and dropped and it stopped and turned violently on the day of the solar eclipse on the Fall equinox and it had the biggest up-day in history, to that date, in points. It broke down in the morning, scared the heck out of traders, turned around and had the biggest up-day in history. Then it rallied for two weeks; at the top of that rally we had the biggest earthquake in Southern California in at least seven years and two days later we had the lunar eclipse, which was the biggest down day in history to date. So the lunar eclipse touched off the earthquake.
Dave: Does astro work the same across all markets?
Arch: These are things that act on emotion and it depends on what markets are moving emotionally at the time. Another thing I discovered in calculating these cycles was the Mars/Uranus cycle and it's just about a two year cycle. The market does not crash every two years but every crash that's taken place in the last 100 years took place in the same 40% of that cycle...every one. So I watch those periods whether we are technically weak or strong, whether we are set up for a possible bad time or not. I said on September 4, 2001 "this market may crash by October 5." The week after the towers fell we had the worst percentage decline since the fall of France in 1940. I also said that there was an event--I think it was Mercury changing direction on the Fall equinox which was September 21--and I said that may make that timeframe more important than normal, and that was the low actually, the 21st--within one day I think Friday was the low and the equinox was Saturday morning. Also, in that September 4, 2001 letter I said the United States will be at war around the weekend of the 7th or 8th of September
Dave: Impressive. What do you see for the near future?
Arch: There was nobody else--astrologer or psychic or card reader or anybody else--that had anything close to that. We are not in that crash period now but the Bradley model shows a high around the middle of July and goes down all the rest of this year. I think it looks pretty bad right now and it could turn down right now. We may have a hard hit for 2-3 days next week and then a rally into July, which may or may not make a higher high and then down the rest of the year. The next crash cycle takes place from August '06 to March '07.
Dave: When you say crash cycle, you mean a major 1987 style event?
Arch: Yes, The Mars/Uranus cycle, where every crash has taken place.
Dave: What do you see for gold?
Arch: I believe gold will hit a high maybe Monday and will then drop into the summer and after that we will have a super up-move in it beginning around Labor Day and going for close to a year. Gold, oil, silver, metals, CRB Index generally. Inflation hedges are ruled by Neptune for whatever reason. I've never paid any attention to rulership they were telling me that when Saturn came up to 0 degrees Leo the price of gold would drop because Saturn is contractive and I said that's horsepuckey. Well, the day that Saturn hit Leo the IMF announced it would sell tons and tons of gold over months and months of time and it was the only limit move that year. But, it was the day Saturn hit in apparent right ascension, which is the way astronomers look at the sky, not ecliptic longitude, which is the way astrologers look at the sky. So I learned a little about rulership stuff and I said "Oh my God." Why should some rulership thing work? I don't know...
Dave: Is the rulership something astrologers learned from the ancients?
Arch: The ancients had it pretty much locked up in terms of what was supposed to happen theoretically in those times, yes.
Dave: Arch, we're almost out of time. I look forward to speaking with you again soon.
Arch: It's been fun and I always enjoy talking about this work; it's meant a lot to me for many many years.
Hi FA,
Do you believe Financial Astrology is useful?
Personally, I don't see the connection with astrology and forecasting securities or markets. Interesed in seeing your opinion.
Hello tarm,
Where do you get intraday updates on NAMO? Thanks in advance.
way to go rayrohn...
Thanks for the tip Dr Worm.
I haven't used the Aroon indicator but I'm going to study up on it.
DrWorm,
I take it you are long TLT. If so, what's your exit target?
The Fosback Index's bad news
By Mark Hulbert, MarketWatch
Last Update: 12:01 AM ET June 8, 2005
ANNANDALE, Va. (MarketWatch) -- Consumers with their low savings rate aren't the only ones who have very little cash left in their bank accounts.
Stock mutual funds don't have much cash, either.
And that's bearish, according to a newsletter editor who 30 years ago devised a market timing indicator based on mutual fund cash levels.
I'm referring to Norman Fosback, currently editor of a service called Fosback's Fund Forecaster. But he is probably better known as editor from the mid 1970s to the late 1990s of the stable of newsletters published by the Institute for Econometric Research - whose flagship service was called Market Logic.
(His editorship of those earlier newsletters came to an end when (TWX: news, chart, profile) Time, Inc. purchased the Institute. As Fosback often reminds his subscribers, the company chose to discontinue those newsletters soon after purchasing them, in the process throwing away several decades' worth of data and research.)
Fortunately, however, historical data on an indicator known as the Fosback Index survive, courtesy of Ned Davis Research.
In essence, the Fosback Index is a modification on the mutual funds' cash-to-assets ratio. The idea behind the Index is to compare the level of funds' current cash holdings with what that level should be, given funds' historical tendencies and current interest rates.
Fosback explains: "The Fosback Index... shows how much cash the funds hold relative to normal liquidity levels. 'Normal' is a function of interest rates because fund managers have an incentive to hold more cash in interest-earning money market securities when interest rates are high and less incentive when rates are low."
Currently, because Fosback calculates that stock mutual fund cash levels are 1.7 percent lower than "normal," the Fosback Index is minus 1.7 percent - which is bearish.
The Fosback Index's track record suggests we pay attention to it. Since 1965, its lowest - and most bearish - reading came in early 2000, right before the Internet bubble burst. Its second-most bearish reading came in 1972, near the top of the market prior to the punishing 1972-74 bear market.
Its highest reading since 1965 was registered in 1990, correctly anticipating the bullish 1990s.
To be sure, the Fosback Index is not perfect. Or, at the very least, its signals can sometimes be very early. It spent most of the last half of the 1990s in negative territory, for example, and so followers of the Index missed out on the explosive years of the latter part of that decade.
So, assuming that the future conforms to the past, the most positive spin we can place on the current Fosback Index reading is that the market decline it is anticipating could still be several years away.
Hardly a ringing endorsement of the market's primary trend.
W@G2~QQQQ 06/08/05 for a 06/10/05 close~
39.01 BULLarkey outside chance and big surprise
38.79 DrWorm
36.86 frenchee
Thanks Bliss!
Bliss
What's your t/a on TLT, SPY, DWCP or $EMW? Thanks.
Spicy Payouts
Boomers' delights: growth stocks that yield 2%-5%
By SHIRLEY A. LAZO
ON APRIL 18, THIS SPACE WAS DEVOTED in large part to what Morgan Stanley's chief U.S. investment strategist, Henry H. McVey, called his "Brave New World thesis" -- that retiring baby boomers are shifting their investment focus toward income and that they'd particularly favor growth stocks with 1%-to-2% dividend yields. But now, he's determined that his theory didn't quite get the story right.
McVey noted that yields had deteriorated. In 1998, for example, retirees' equity investments "generated an average dividend yield of fully 2.6%, versus an average of just 0.8% among younger investors." So, they were hungry for fatter payouts.
However, McVey says that, after his report was published, some boomers and their financial advisers let him know that "the sweet spot for [his] Brave New World thesis is not the 1%-2% dividend-yielding stocks with double-digit earnings growth" that he highlighted in his April piece. Instead, he says in a new report, "these investors are willing to give up a little -- but not a lot -- on the growth front to get more of the proverbial bird in the hand earlier in the game." Thus, the sweet spot, from what he can tell, is "2%-5%-yielding stocks with 5%-15% earnings growth."
McVey says he was amazed at how hard it was to find a lot of stocks in this category, but he still managed to put together a basket of 20, which outperformed the S&P 500 by 4.6 percentage points this year, through late May. Sixty percent of the stocks are in just three industry groups: banks, capital goods, and pharmaceutical and biotech. In his view, they offer the prospect of market-level returns (roughly 13% over the next two years) but with less risk than the broad market. They are:
Wachovia (ticker: WB), Wells Fargo (WFC), Washington Mutual (WM), Bank of America (BAC), Masco (MAS), General Electric (GE), 3M (MMM), Emerson Electric (EMR), Harrah's Entertainment (HET), Kinder Morgan (KMI), Kellogg (K), Altria Group (MO), Procter & Gamble (PG), Eli Lilly (LLY), Abbott Laboratories (ABT), Pfizer (PFE), Wyeth (WYE), Genuine Parts (GPC), Edison International (EIX) and Exelon (EXC).
McVey found that, "at times when there has been a sudden spike in market volatility, the volatility of this portfolio has typically remained muted." His conclusion: "These stocks offer most of the market's spice, but with significantly less heartburn."
ROBERT WILLENS, LEHMAN BROTHERS' managing director and tax-accounting expert, recently zeroed in on an Internal Revenue Service ruling that makes dividend income even more attractive, from a tax viewpoint, than originally thought.
This one, ruling 2005-31, lets a mutual fund with both domestic and foreign shareholders allocate all of its qualified dividend income to the domestic investors, whose dividends are taxed at a maximum rate of 15%. It had been believed that a portion of the qualified dividend had to be allocated to the foreign shareholders, who are ineligible for any such tax break.
Willens provides an example: Say, a mutual fund earned for the taxable year $10,000 of qualified dividend income, $10,000 of qualified interest income, $5,000 of net short-term capital gains and $5,000 of net long-term capital gains. The fund incurred $10,000 of general and administrative expenses and distributed $20,000 to its investors.
Shareholder A, a U.S. citizen, received a distribution amounting to $20, as did Shareholder B, a nonresident alien. According to Willens, "the first step was to ascertain the maximum amounts the fund could designate as capital-gain dividends, qualified dividend income, short-term capital-gain dividends and interest-related dividends." Except for interest-related dividends (which had to be reduced by the allocable share of the fund's expenses; for this example, the final amount was calculated at $6,000), it was the gross amount for each variety. The $26,000 total of the maximum amounts exceeded the total amount distributed ($20,000), but the IRS ruling concludes, nonetheless, that the fund "may designate each of the maximum amounts, even though the aggregate of such maximums exceeds the total distributions," says Willens.
The second part of the ruling holds that the U.S. shareholder and the nonresident alien "may apply different designations to their distributions." Accordingly, of the $20 distributed to the American, $10 consists of qualified dividend income, and $5 is capital gains -- in each case taxed at the maximum rate of 15%. Only the remaining $5 is treated as unqualified dividend income. For the nonresident alien shareholder, $5 is a capital-gains dividend, $6 is an interest-related dividend and $5 constitutes a short-term capital-gain dividend. Willens explains, there is no withholding with respect to these elements of the distribution. Only the $4 balance of the distribution was ordinary dividend income.
The message, says Willens, "is that a mutual fund need not apportion each variety of income to each of its shareholders in strict proportion to their relative shareholdings. Income that is tax-favored in the hands of one type of shareholder can be disproportionately allocated to such shareholder with the result that the aggregate taxes derived from mutual funds, thanks to the IRS's surprising concession, will be minimized."