The Company qualifies as a REIT under the Internal Revenue Code of 1986, as amended, for federal income tax purposes. In order to maintain the Company’s status as a REIT, the Company must annually distribute at least 90% of its REIT taxable income, subject to certain adjustments and excluding any net capital gain, to its stockholders. For the years ended December 31, 2025, 2024 and 2023, the Company’s REIT taxable income (loss) was $5,304 (unaudited), $(5,915) (unaudited) and $(3,532) (unaudited), respectively.

The Company had no uncertain tax positions as of December 31, 2025 or 2024. The Company had no interest or penalties relating to income taxes recognized on the consolidated statements of operations and comprehensive loss for the years ended December 31, 2025, 2024 and 2023. As of December 31, 2025, returns for the calendar years 2022, 2023, 2024 and 2025 remain subject to examination by U.S. and various state and local tax jurisdictions.

During the year ended December 31, 2018, the Company recorded a $15,405 impairment for the Mainstreet JV recorded on its consolidated statement of operations and comprehensive loss. The Company’s investment in Mainstreet JV was held through a taxable REIT subsidiary. Based on an effective tax rate of 28.51%, which is calculated by combining a 21% Federal tax rate and an IL tax rate

of 7.51% (9.5% state rate net of the Federal benefit), the deferred tax benefit related to the impairment was approximately $4,400. Since the taxable REIT subsidiary did not conduct any activities outside the investment in Mainstreet JV, management concluded it was not more likely than not that the taxable REIT subsidiary would be able to utilize these losses in future tax periods and recorded a full valuation allowance of $4,400 during the year ended December 31, 2018. The Mainstreet JV was liquidated for income tax purposes in 2019, resulting in a $1,560 reduction in the deferred tax asset and valuation allowance. As of December 31, 2024, the taxable REIT subsidiary’s capital loss carryforward of $9,931 expired, resulting in a write-off of the remaining deferred tax asset and corresponding valuation allowance, with a zero net impact to income tax expense. No income tax expense or benefit was recorded during the years ended December 31, 2025, 2024 and 2023.

During 2025, 2024 and 2023, the Company declared quarterly distributions in an amount equal to $0.135600 per share, which represented an annualized rate of 3%, 3% and 3% based on the previously Estimated Per Share NAV as of September 30, 2025, December 31, 2023 and December 31, 2022, respectively, payable in arrears the following quarter.

The table below presents the distributions declared and paid during the years ended December 31, 2025, 2024 and 2023.


	December 31,
	2025		2024		2023
Distributions paid	$	19,590	$	19,602	$	19,636
Distributions declared	$	19,591	$	19,595	$	19,634

For federal income tax purposes, distributions may consist of ordinary dividend income, qualified dividend income, non-taxable return of capital, capital gains or a combination thereof. Distributions to the extent of the Company’s current and accumulated earnings and profits for federal income tax purposes are taxable to the recipient as either ordinary dividend income or, if so declared by the Company, qualified dividend income or capital gain dividends. Distributions in excess of these earnings and profits (calculated for income tax purposes) constitute a non-taxable return of capital rather than ordinary dividend income or a capital gain dividend and reduce the recipient’s tax basis in the shares to the extent thereof. Distributions in excess of earnings and profits that reduce a recipient’s tax basis in the shares have the effect of deferring taxation of the amount of the distribution until the sale of the stockholder’s shares. If the recipient's tax basis is reduced to zero, distributions in excess of the aforementioned earnings and profits (calculated for income tax purposes) constitute taxable gain.

The following table sets forth the taxability of distributions on common shares, on a per share basis, paid in 2025, 2024 and 2023:


	2025		2024		2023
Ordinary income	$	0.15	$	—	$	—
Capital gain	$	—	$	—	$	—
Nontaxable return of capital	$	0.39	$	0.54	$	0.54