Actually yes, they can and do. Cfr the link to the SEC I posted; they end the information with "If you have questions about specific dividends, you should consult with your financial advisor".
As you've pointed out; the rules with >25% dividends are a mine-field and SIAF has NOT stated that their distribution have any exceptions to the rule. I'm not familiar with other >25% dividends in the US, but do other companies warn people about the special rules in their PRs about those dividends? (I assume not, but I haven't checked)
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