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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549


FORM N-CSR

CERTIFIED SHAREHOLDER REPORT OF REGISTERED
MANAGEMENT INVESTMENT COMPANIES


Investment Company Act file number 811-07528


Special Opportunities Fund, Inc.
(Exact name of registrant as specified in charter)



615 East Michigan Street
Milwaukee, WI 53202
(Address of principal executive offices) (Zip code)


Andrew Dakos
Bulldog Investors, LLP
Park 80 West
250 Pehle Avenue, Suite 708
Saddle Brook, NJ 07663
(Name and address of agent for service)

Copy to:
Thomas R. Westle, Esq
Blank Rome LLP
1271 Avenue of the Americas
New York, NY 10020

1-877-607-0414
Registrant's telephone number, including area code



Date of fiscal year end: 12/31/2023


Date of reporting period:  12/31/2023



Item 1. Reports to Stockholders.

(a)



Special Opportunities Fund, Inc.
(SPE)
Annual Report
For the year ended
December 31, 2023













Special Opportunities Fund, Inc.


Managed Distribution Plan (unaudited)
 
On March 4, 2019, the Special Opportunities Fund (the “Fund”) received authorization from the SEC that permits the Fund to distribute long-term capital gains to stockholders more than once per year. Accordingly, on April 1, 2019, the Fund announced its Board of Directors formally approved the implementation of a Managed Distribution Plan (“MDP”) to make monthly cash distributions to stockholders.
 
In the year ended December 31, 2023, the Fund made monthly distributions to common stockholders at an annual rate of 8%, based on the NAV of the Fund’s common shares as of the close of business on the last business day of the previous year. You should not draw any conclusions about the Fund’s investment performance from the amount of these distributions or from the terms of the MDP. The MDP will be subject to regular periodic review by the Fund’s Board of Directors.
 
With each distribution, the Fund will issue a notice to stockholders which will provide detailed information regarding the amount and composition of the distribution and other information required by the Fund’s exemptive order. The Fund’s Board of Directors may amend or terminate the MDP at any time without prior notice to stockholders; however, at this time, there are no reasonably foreseeable circumstances that might cause the termination of the MDP. For tax reporting purposes the actual composition of the total amount of distributions for each year will continue to be provided on a Form 1099-DIV issued after the end of the year.
 
The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, is available on the Fund’s website at www.specialopportunitiesfundinc.com.


1

Special Opportunities Fund, Inc.


February 29, 2024
 
Dear Fellow Shareholder:
 
The stock market continued to advance in the second half of 2023, with the S&P 500 Index gaining 8.04%. After accounting for distributions, the Fund’s net asset value per common share (NAV) rose by 10.05% in the second half of 2023. For the entire year, the Fund’s NAV return was 18.83% vs. 26.29% for the S&P 500 Index. As of December 31, 2023, the trading discount of the Fund’s common shares was 17.06%. Since then, the discount has narrowed by about 1%. From late April 2023 through the end of 2023, the Fund has repurchased 452,787 of its common shares at discounts of at least 15% and 80,397 preferred shares at a discount to their book value of $25. The details about our repurchases are posted monthly on the Fund’s website.
 
The Fund has a managed distribution plan that calls for monthly distributions to common shareholders at an annual rate of at least 8% of the NAV as of the last trading day of the prior year. On December 29, 2023, the NAV was $14.30. Therefore, the minimum monthly distribution for 2024 is $0.0954 per share.
 
As a reminder, on January 21, 2022, the Fund completed a rights offering for shares of Convertible Preferred Stock, Series C, at $25 per share which pay quarterly distributions at a rate of 2.75% per annum. The preferred shares may be converted into common stock initially at a price of $20.50 per share (or a ratio of 1.2195 shares of common stock for each share of Series C Stock) and is adjusted for any distributions to common stockholders. Please refer to the prospectus, which is available on the SEC’s website, for full details regarding the Series C stock. The current conversion ratio and diluted NAV of the Fund’s common shares (assuming all Series C shares are converted to common shares) are posted weekly on the Fund’s website.
 
Investment Update and Commentary
 
In the second half of 2023, we saw greater value in discounted closed-end funds (CEFs) and business development companies (BDCs). Consequently, we increased the Fund’s exposure to these investments from 67.5% of investable assets to 71.1%. In addition, with fewer IPOs for special purpose acquisition companies (SPACs) and a substantial number of SPAC maturities, i.e., liquidations or mergers, the percentage of the Fund’s total investable assets in SPACs fell from 16.5% to 14.7%. We see an investment in a pre-merger SPAC as an alternative to a money market fund with a degree of optionality. As a rule, we almost never hold a SPAC’s common stock after a business combination. As of the end of 2023, the balance of the Fund’s portfolio consisted of a smattering of shares of undervalued operating companies, notes, and about 5% in cash equivalents.
 
In our last letter, we predicted that a decision by a judge in the District Court for the Southern District of New York (SDNY) concluding that a bylaw placing so-called


2

Special Opportunities Fund, Inc.


“control share” limitations on voting by shareholders of CEFs “violates Section 18(i) of the Investment Company Act of 1940” would be upheld on appeal. That turned out to be an accurate prediction. A Massachusetts state court had previously reached the same conclusion. On June 29, 2023, yet another lawsuit was filed in the SDNY against a number of Maryland-based CEFs to invalidate similar control share prohibitions on stockholder voting. The judge in that case quickly ruled for the plaintiff and although that decision is being appealed, we foresee little chance of it being successful. In early January 2024, one CEF issued a poison pill that effectively limits the number of shares any shareholder can acquire. Shortly thereafter, the largest shareholder sued to have the poison pill invalidated. It is disappointing, to say the least, that the SEC, which is authorized to enforce the securities laws, has taken a “hands off” approach regarding attempts by managements of investment companies to undermine the voting rights of shareholders. As a result, shareholders have had to engage in costly, inefficient, and time-consuming private litigation to protect their voting rights.
 
We were able to sell all our shares of First Trust Dynamic Europe Equity Income Fund (FDEU) at prices very close to NAV. In late 2022, we asked FDEU’s Board of Trustees to recommend converting FDEU to an open-end fund, which it was required to propose to stockholders in 2023. The Board refused so we solicited proxies to elect our nominees as Trustees. The Board refused to count our votes, claiming that our nominees were ineligible. Apparently embarrassed about the prospect of losing the election, a few days before the stockholder meeting, FDEU announced that it would become an exchange-traded fund (“ETF”) by the end of 2023. Despite that welcome result, which effectively eliminated the discount, we sued the Board and the manager because we believe disenfranchising shareholders should not go unchallenged. After we sued, the Board rescinded FDEU’s illegal control share bylaw. As a result, we have filed a motion for an award of legal fees for obtaining a “common benefit” for FDEU’s stockholders. Unsurprisingly, management is opposing our motion.
 
In our last letter, we noted that, after having given notice of our intent to nominate trustees of MFS High Yield Municipal Trust (CMU) and MFS Investment Grade Municipal Trust (CXH), we reached a settlement agreement with management. At the time, the discount for each of these CEFs was about 14%. The settlement provided for a modest self-tender offer by each fund and a commitment to provide a full liquidity event in two years unless the discount shrinks to no more than 7.5%. The discount for each fund is still in double-digits, which we think is unjustifiably high. Consequently, the Fund is maxed out in both CMU and CHX and it is hard to envision them not outperforming almost every open-end municipal bond fund over the next two years.
 
The Fund has a meaningful stake in shares of Destra Multi-Alternative Fund (DMA). More than half of DMA’s total assets are unquoted private investment


3

Special Opportunities Fund, Inc.


vehicles. Last spring, after eliminating its monthly dividend, DMA’s shares fell to a discount of more than 50%. We then reached out to management to discuss options to enhance stockholder value. On October 6, 2023, DMA announced that “unless certain targets are met, [it] will dissolve at the close of business on March 31, 2027.” In addition, a representative of a large shareholder was invited to join DMA’s Board of Trustees. That gives us more confidence that (1) the valuations of DMA’s private holdings are not reasonable, and (2) management will not be tempted to renege on its commitment to dissolve. As Ronald Reagan used to say, “Trust but verify.” DMA’s stock has risen since the announcement, and the discount has narrowed significantly, to about 30%. Hopefully, it will continue to narrow. Otherwise, we may push for an earlier windup.
 
In essence, CMU, CXH, and DMA are now quasi term trusts, i.e., funds with a limited life and that have committed to either wind up or provide a liquidity event at some point if certain conditions are met. There are currently about fifty closed-end term trusts with terms that expire as early as several months from today to more than ten years. The obvious attraction of these funds is that any discount will eventually be eliminated. We have been increasing our exposure to some of these funds depending on a number of factors, including the current discount and the time to maturity. For example, Nuveen Preferred & Income Term Fund (JPI) is slated to wind up in just six months and it is trading at a 3 to 4% discount to NAV. Interestingly, JPI has announced that it will ask stockholders to approve eliminating its fixed life and, if approved, will conduct a self-tender offer for 100% of its shares at NAV. Either way, shareholders should be able to monetize their shares at NAV in about six months. Overall, JPI currently looks like an attractive investment because of the built in “alpha” by elimination of the discount.
 
This year, we expect to be quite active in enhancing the value of the Fund’s investments. We have already submitted proposals to Principal Real Estate Income Fund (PGZ), Tortoise Energy Independence Fund (NDP), Tortoise Power and Energy Infrastructure Fund (TPZ), and Virtus Total Return Fund (ZTR). We also anticipate engaging with the management of other companies whose shares we believe are undervalued and that have not taken steps to address the disparity.
 
A settlement was approved by the court in our class action lawsuit against FAST Acquisition Corp. (FST), a SPAC that was slated to liquidate. We alleged that FST’s remaining assets should have been equitably distributed to all stockholders. The Fund owned about 555,000 shares of FST, which were cancelled and consequently are not being valued. The settlement provides for a payment of slightly more than fifty cents per share plus $5,000 to be paid to the Fund for serving as the lead plaintiff. We hope to receive payment in the near future.
 
Our largest investment in an operating company is shares of Texas Pacific Land (TPL), a profitable asset-rich company that owns land in West Texas, primarily in


4

Special Opportunities Fund, Inc.


the Permian Basin. Traditionally, TPL has generated revenue through rental and royalty payments by oil and gas producers. We believe that its potential is not being fully realized and that senior management wants to use TPL’s shares and cash to invest in other businesses with lower margins to justify their extremely high compensation. A settlement agreement with TPL’s largest shareholder required it to vote its shares in accordance with the Board’s recommendation as long as its representative is on the board. We have reason to believe that the composition of the Board is likely to change in the next year or two. If so, that could be the catalyst for an increased stock price.
 
As always, please note that instruction forms for voting proxies for certain CEFs held by the Fund are available at http://www.specialopportunitiesfundinc.com/proxy_voting.html. To be notified directly of such instances, please email us at proxyinstructions@bulldoginvestors.com.
 
Sincerely yours,


Phillip Goldstein
Chairman
 






5

Special Opportunities Fund, Inc.


Growth of $10,000 Investment

Performance at a glance (unaudited)
 
Average annual total returns for common stock for the periods ended 12/31/2023
     
Net asset value returns
1 year
5 years
10 years
Special Opportunities Fund, Inc.
18.74%
  9.55%
  5.63%
Market price returns
     
Special Opportunities Fund, Inc.
14.13%
  9.97%
  5.42%
Index returns
     
S&P 500® Index
26.29%
15.69%
12.03%
Share price as of 12/31/2023
     
Net asset value
   
$14.30
Market price
   
$11.86

Past performance does not predict future performance. The return and value of an investment will fluctuate so that an investor’s share, when sold, may be worth more or less than their original cost. The Fund’s common stock net asset value (“NAV”) return assumes, for illustration only, that dividends and other distributions, if any, were reinvested at the NAV on the ex-dividend date. The Fund’s common stock market price returns assume that all dividends and other distributions, if any, were reinvested at the lower of the NAV or the closing market price on the ex-dividend date. NAV and market price returns for the period of less than one year have not been annualized. Returns do not reflect the deduction of taxes that a shareholder could pay on Fund dividends and other distributions, if any, or the sale of Fund shares.
 
The S&P 500® Index is a capital weighted, unmanaged index that represents the aggregate market value of the common equity of 500 stocks primarily traded on the New York Stock Exchange. You cannot invest directly in an index.
 

6

Special Opportunities Fund, Inc.


Portfolio composition as of 12/31/2023(1) (Unaudited)
 
   
Value
   
Percent
 
Investment Companies
 
$
152,393,478
     
71.44
%
Special Purpose Acquisition Vehicles
   
31,564,441
     
14.80
 
Money Market Funds
   
10,255,081
     
4.81
 
Other Common Stocks
   
9,243,834
     
4.33
 
Unsecured Notes
   
4,792,252
     
2.25
 
Corporate Obligations
   
1,598,381
     
0.75
 
Trusts
   
1,527,009
     
0.72
 
Real Estate Investment Trusts
   
1,414,054
     
0.66
 
Preferred Stocks
   
345,678
     
0.16
 
Warrants
   
118,787
     
0.06
 
Rights
   
49,166
     
0.02
 
Total Investments
 
$
213,302,161
     
100.00
%

(1)
As a percentage of total investments.

The following table represents the Fund’s investments categorized by country as of December 31, 2023:
 
   
% of Total
   
Country
 
Investments
   
United States
   
96.22
%
 
China
   
1.16
%
 
Hong Kong
   
1.01
%
 
Guernsey
   
0.86
%
 
Ireland
   
0.75
%
 
Cayman Islands
   
0.00
%
 
     
100.00
%
 


7

Special Opportunities Fund, Inc.


Portfolio of investments—December 31, 2023

   
Shares
   
Value
 
INVESTMENT COMPANIES—96.76%
           
Closed-End Funds—82.41%
           
abrdn Global Dynamic Dividend Fund
   
49,874
   
$
465,823
 
Apollo Tactical Income Fund, Inc.
   
37,375
     
521,755
 
Bancroft Fund Ltd.
   
22,345
     
357,073
 
BlackRock California Municipal Income Trust
   
229,380
     
2,759,441
 
BlackRock ESG Capital Allocation Term Trust
   
73,787
     
1,190,184
 
Blackstone Strategic Credit 2027 Term Fund
   
86,455
     
978,671
 
BNY Mellon Alcentra Global Credit Income 2024 Target Term Fund, Inc.
   
46,559
     
379,456
 
BNY Mellon Municipal Income, Inc.
   
621,787
     
4,041,615
 
BNY Mellon Strategic Municipal Bond Fund, Inc.
   
468,928
     
2,677,579
 
Carlyle Credit Income Fund
   
153,336
     
1,219,021
 
Central and Eastern Europe Fund, Inc.
   
188,883
     
1,841,609
 
Central Securities Corp.
   
219,394
     
8,286,511
 
ClearBridge Energy Midstream Opportunity Fund, Inc. (a)
   
2,349
     
82,027
 
ClearBridge MLP & Midstream Fund, Inc.
   
8,213
     
329,259
 
ClearBridge MLP & Midstream Total Return Fund, Inc. (a)
   
186
     
6,739
 
Destra Multi-Alternative Fund
   
216,567
     
1,349,212
 
Dividend and Income Fund
   
350,673
     
4,267,690
 
DWS Municipal Income Trust
   
1,117,608
     
9,935,535
 
DWS Strategic Municipal Income Trust
   
256,315
     
2,217,125
 
Eaton Vance New York Municipal Bond Fund
   
423,341
     
4,085,241
 
Ellsworth Growth and Income Fund Ltd.
   
76,934
     
621,627
 
Federated Hermes Premier Municipal Income Fund
   
4,839
     
53,181
 
First Trust High Yield Opportunities 2027 Term Fund
   
71,825
     
1,000,522
 
First Trust MLP and Energy Income Fund
   
15,392
     
131,909
 
Gabelli Dividend & Income Trust
   
123,595
     
2,674,596
 
General American Investors Co., Inc.
   
324,541
     
13,939,036
 
Herzfeld Caribbean Basin Fund, Inc.
   
1,941
     
5,396
 
High Income Securities Fund
   
242,733
     
1,558,346
 
Highland Opportunities and Income Fund
   
310,059
     
2,384,354
 
Invesco High Income 2024 Target Term Fund
   
201,622
     
1,389,176
 
Mexico Equity & Income Fund, Inc.
   
100,100
     
1,121,120
 
MFS High Yield Municipal Trust
   
741,292
     
2,453,677
 
MFS Investment Grade Municipal Trust
   
213,211
     
1,614,007
 
Miller/Howard High Dividend Fund
   
8,331
     
88,392
 
Morgan Stanley Emerging Markets Debt Fund, Inc.
   
175,052
     
1,216,611
 

The accompanying notes are an integral part of these financial statements.
8

Special Opportunities Fund, Inc.


Portfolio of investments—December 31, 2023

   
Shares
   
Value
 
INVESTMENT COMPANIES—(continued)
           
Closed-End Funds—(continued)
           
Morgan Stanley Emerging Markets Domestic Debt Fund, Inc.
   
162,390
   
$
756,737
 
Neuberger Berman Municipal Fund, Inc.
   
30,225
     
312,829
 
Neuberger Berman Next Generation Connectivity Fund, Inc.
   
535,671
     
5,854,884
 
New America High Income Fund, Inc.
   
91,191
     
641,985
 
Nuveen Floating Rate Income Fund
   
242,798
     
1,995,800
 
Nuveen Multi-Asset Income Fund
   
12,779
     
157,182
 
NXG NextGen Infrastructure Income Fund
   
65,522
     
2,328,652
 
Pershing Square Holdings Ltd. Fund
   
30,000
     
1,370,502
 
Pershing Square Holdings Ltd. Fund
   
10,000
     
467,000
 
Principal Real Estate Income Fund
   
201,915
     
1,908,097
 
Royce Value Trust, Inc.
   
83,173
     
1,210,999
 
Saba Capital Income & Opportunities Fund
   
249,557
     
1,924,084
 
SRH Total Return Fund, Inc.
   
1,116,522
     
15,486,160
 
Taiwan Fund, Inc.
   
223,819
     
7,741,899
 
Templeton Global Income Fund
   
48,267
     
182,932
 
The Swiss Helvetia Fund, Inc.
   
236,992
     
1,943,334
 
Tortoise Energy Independence Fund, Inc.
   
49,741
     
1,425,577
 
Tortoise Power and Energy Infrastructure Fund, Inc.
   
147,267
     
2,063,859
 
Virtus Convertible & Income 2024 Target Term Fund
   
17,054
     
148,711
 
Virtus Total Return Fund, Inc.
   
805,935
     
4,440,702
 
Western Asset Global Corporate Defined Opportunity Fund, Inc.
   
287
     
3,665
 
Western Asset Intermediate Muni Fund, Inc.
   
24,397
     
187,857
 
             
129,796,963
 
                 
Business Development Companies—14.35%
               
Barings BDC, Inc.
   
403,900
     
3,465,462
 
CION Investment Corp.
   
899,218
     
10,170,156
 
FS KKR Capital Corp.
   
213,874
     
4,271,064
 
Logan Ridge Finance Corp.
   
81,161
     
1,835,050
 
PennantPark Investment Corp.
   
67,321
     
465,188
 
Portman Ridge Finance Corp.
   
98,369
     
1,789,332
 
SuRo Capital Corp. (a)
   
152,351
     
600,263
 
     
     
22,596,515
 
Total Investment Companies (Cost $136,915,078)
           
152,393,478
 

The accompanying notes are an integral part of these financial statements.
9

Special Opportunities Fund, Inc.


Portfolio of investments—December 31, 2023

   
Shares/Units
   
Value
 
SPECIAL PURPOSE ACQUISITION VEHICLES—20.04%
           
99 Acquisition Group, Inc. (a)
   
154,727
   
$
1,576,668
 
Agriculture & Natural Solutions Acquisition Corp. Units (a)
   
25,000
     
253,750
 
Alpha Partners Technology Merger Corp. (a)
   
37,224
     
398,297
 
AP Acquisition Corp. (a)
   
193,647
     
2,155,291
 
Ares Acquisition Corp. II (a)
   
161,985
     
1,691,123
 
Arrowroot Acquisition Corp. (a)
   
50,000
     
523,500
 
Churchill Capital Corp. VII (a)
   
124,920
     
1,311,660
 
Colombier Acquisition Corp. II Units (a)
   
61,998
     
624,940
 
EVe Mobility Acquisition Corp. (a)
   
34,200
     
369,702
 
Four Leaf Acquisition Corp. (a)
   
67,644
     
710,938
 
Global Lights Acquisition Corp. (a)
   
246,417
     
2,483,883
 
Gores Holdings IX, Inc. (a)
   
104,060
     
1,092,630
 
Haymaker Acquisition Corp. 4 (a)
   
179,631
     
1,844,810
 
Inflection Point Acquisition Corp. II (a)
   
244,733
     
2,528,092
 
Investcorp Europe Acquisition Corp. I (a)
   
154,932
     
1,707,351
 
Quetta Acquisition Corp. (a)
   
167,742
     
1,695,872
 
Screaming Eagle Acquisition Corp. (a)
   
491,801
     
5,213,091
 
Spring Valley Acquisition Corp. II (a)
   
130,332
     
1,408,889
 
TG Venture Acquisition Corp. (a)
   
309,207
     
3,351,804
 
Trailblazer Merger Corp. I (a)
   
59,479
     
622,150
 
Total Special Purpose Acquisition Vehicles (Cost $30,976,559)
           
31,564,441
 
                 
   
Shares
         
PREFERRED STOCKS—0.22%
               
Diversified REITs—0.21%
               
NexPoint Diversified Real Estate Trust
   
22,324
     
337,092
 
                 
Office REITs—0.01%
               
Brookfield DTLA Fund Office Trust Investor, Inc.
   
171,723
     
8,586
 
Total Preferred Stocks (Cost $4,932,717)
           
345,678
 
                 
OTHER COMMON STOCKS—5.87%
               
Biotechnology—0.39%
               
Cyteir Therapeutics, Inc. (a)
   
200,000
     
608,000
 
                 
Financial Services—0.16%
               
Cannae Holdings, Inc. (a)
   
12,980
     
253,240
 
                 

The accompanying notes are an integral part of these financial statements.
10

Special Opportunities Fund, Inc.


Portfolio of investments—December 31, 2023

   
Shares
   
Value
 
Food Products—0.26%
           
Limoneira Co.
   
20,000
   
$
412,600
 
                 
Oil, Gas & Consumable Fuels—4.39%
               
Texas Pacific Land Corp.
   
4,400
     
6,918,780
 
                 
Real Estate Management & Development—0.67%
               
Howard Hughes Holdings, Inc. (a)
   
12,000
     
1,026,600
 
Trinity Place Holdings, Inc. (a)
   
221,748
     
24,614
 
             
1,051,214
 
Total Other Common Stocks (Cost $7,675,035)
           
9,243,834
 
                 
TRUSTS—0.97%
               
Copper Property CTL Pass Through Trust
   
151,189
     
1,527,009
 
Lamington Road Grantor Trust (a)(c)
   
320,690
     
0
 
Total Trusts (Cost $1,758,153)
           
1,527,009
 
                 
REAL ESTATE INVESTMENT TRUSTS—0.90%
               
NexPoint Diversified Real Estate Trust
   
177,868
     
1,414,054
 
Total Real Estate Investment Trusts (Cost $2,327,359)
           
1,414,054
 
                 
   
Principal
         
   
Amount
         
CORPORATE OBLIGATIONS—1.01%
               
Lamington Road DAC (b)(c)
               
  8.000%, 04/07/2121
 
$
17,203,693
     
688,148
 
  9.750%, 04/07/2121
   
1,753,821
     
910,233
 
Total Corporate Obligations (Cost $6,256,237)
           
1,598,381
 
                 
UNSECURED NOTES—3.04%
               
Legacy IMBDS, Inc. (c)
               
  8.500%, 09/30/2026
   
23,458
     
0
 
Sachem Capital Corp.
               
  7.125%, 06/30/2024
   
60,000
     
1,500,000
 
  7.750%, 09/30/2025
   
120,000
     
2,864,652
 
  6.000%, 03/30/2027
   
20,000
     
427,600
 
             
4,792,252
 
Total Unsecured Notes (Cost $5,546,450)
           
4,792,252
 

The accompanying notes are an integral part of these financial statements.
11

Special Opportunities Fund, Inc.


Portfolio of investments—December 31, 2023

   
Shares
   
Value
 
WARRANTS—0.07%
           
Alset Capital Acquisition Corp.
           
  Expiration: February 2027
           
  Exercise Price: $11.50 (a)
   
23,750
   
$
237
 
Andretti Acquisition Corp.
               
  Expiration: March 2028
               
  Exercise Price: $11.50 (a)
   
72,334
     
18,084
 
Blockchain Coinvestors Acquisition Corp. I
               
  Expiration: November 2028
               
  Exercise Price: $11.50 (a)
   
32,500
     
1,625
 
Cactus Acquisition Corp. 1 Ltd.
               
  Expiration: October 2026
               
  Exercise Price: $11.50 (a)
   
40,700
     
1,221
 
Cartesian Growth Corp. II
               
  Expiration: July 2028
               
  Exercise Price: $11.50 (a)
   
21,986
     
2,858
 
Churchill Capital Corp. VII
               
  Expiration: February 2028
               
  Exercise Price: $11.50 (a)
   
24,984
     
3,997
 
Corner Growth Acquisition Corp.
               
  Expiration: December 2027
               
  Exercise Price: $11.50 (a)
   
33,333
     
2,067
 
Corner Growth Acquisition Corp. 2
               
  Expiration: June 2026
               
  Exercise Price: $11.50 (a)
   
14,366
     
431
 
Digital Health Acquisition Corp.
               
  Expiration: November 2028
               
  Exercise Price: $11.50 (a)
   
116,000
     
3,074
 
Global Gas Corp.
               
  Expiration: October 2027
               
  Exercise Price: $11.50 (a)
   
19,300
     
618
 
HNR Acquisition Corp.
               
  Expiration: July 2028
               
  Exercise Price: $11.50 (a)
   
63,000
     
3,622
 
iCoreConnect, Inc.
               
  Expiration: May 2028
               
  Exercise Price: $11.50 (a)
   
150,000
     
30
 
Insight Acquisition Corp.
               
  Expiration: August 2026
               
  Exercise Price: $11.50 (a)
   
12,450
     
251
 

The accompanying notes are an integral part of these financial statements.
12

Special Opportunities Fund, Inc.


Portfolio of investments—December 31, 2023

   
Shares
   
Value
 
WARRANTS—(continued)
           
Investcorp Europe Acquisition Corp. I
           
  Expiration: November 2028
           
  Exercise Price: $11.50 (a)
   
150,000
   
$
34,380
 
Keyarch Acquisition Corp.
               
  Expiration: July 2028
               
  Exercise Price: $11.50 (a)
   
75,000
     
1,313
 
Lamington Road
               
  Expiration: July 2025
               
  Exercise Price: $0.20 (a)(c)(e)
   
640,000
     
0
 
Landcadia Holdings IV, Inc.
               
  Expiration: March 2028
               
  Exercise Price: $11.50 (a)
   
25,000
     
1,622
 
NKGen Biotech, Inc.
               
  Expiration: October 2028
               
  Exercise Price: $11.50 (a)
   
17,677
     
1,428
 
Northern Star Investment Corp. III
               
  Expiration: February 2028
               
  Exercise Price: $11.50 (a)
   
17,833
     
75
 
Northern Star Investment Corp. IV
               
  Expiration: December 2027
               
  Exercise Price: $11.50 (a)
   
8,833
     
11
 
Plutonian Acquisition Corp.
               
  Expiration: October 2027
               
  Exercise Price: $11.50 (a)
   
101,969
     
3,049
 
Quantum FinTech Acquisition Corp.
               
  Expiration: December 2027
               
  Exercise Price: $11.50 (a)
   
76,000
     
3,906
 
Screaming Eagle Acquisition Corp.
               
  Expiration: December 2027
               
  Exercise Price: $11.50 (a)
   
75,200
     
33,848
 
TG Venture Acquisition Corp.
               
  Expiration: August 2028
               
  Exercise Price: $11.50 (a)
   
100,000
     
1,040
 
ZyVersa Therapeutics, Inc.
               
  Expiration: December 2027
               
  Exercise Price: $11.50 (a)(c)(e)
   
65,250
     
0
 
Total Warrants (Cost $418,693)
           
118,787
 

The accompanying notes are an integral part of these financial statements.
13

Special Opportunities Fund, Inc.


Portfolio of investments—December 31, 2023

   
Shares
   
Value
 
RIGHTS—0.03%
           
Alset Capital Acquisition Corp. (a)
   
47,500
   
$
9,975
 
Hudson Acquisition I Corp. (Expiration: April 18, 2024) (a)
   
25,100
     
3,966
 
Keyarch Acquisition Corp. (a)
   
150,000
     
9,405
 
Nocturne Acquisition Corp. (a)
   
75,000
     
12,360
 
Plutonian Acquisition Corp. (Expiration: August 15, 2024) (a)
   
101,969
     
13,460
 
Total Rights (Cost $74,774)
           
49,166
 
                 
MONEY MARKET FUNDS—6.51%
               
Fidelity Institutional Government Portfolio—Class I, 5.240% (d)
   
5,127,540
     
5,127,540
 
Invesco Treasury Portfolio—Institutional Class, 5.262% (d)
   
5,127,541
     
5,127,541
 
Total Money Market Funds (Cost $10,255,081)
           
10,255,081
 
Total Investments (Cost $207,136,136)—135.45%
           
213,302,161
 
Other Assets in Excess of Liabilities—0.33%
           
562,133
 
Preferred Stock—(35.78)%
           
(56,363,925
)
TOTAL NET ASSETS—100.00%
         
$
157,500,369
 

Percentages are stated as a percent of net assets.
(a)
Non-income producing security.
(b)
The coupon rate shown represents the rate at December 31, 2023.
(c)
Fair valued securities. The total market value of these securities was $1,598,381, representing 1.01% of net assets. Value determined using significant unobservable inputs.
(d)
The rate shown represents the seven-day yield at December 31, 2023.
(e)
Illiquid securities. The total market value of these securities was $0, representing 0.00% of net assets.

The Schedule of Investments incorporates the Global Industry Classification Standard (GICS®). GICS was developed by and/or is the exclusive property of MSCI, Inc. and Standard & Poors Financial Services LLC (“S&P”). GICS is a service mark of MSCI and S&P and has been licensed for use by U.S. Bancorp Fund Services, LLC.

The accompanying notes are an integral part of these financial statements.
14

Special Opportunities Fund, Inc.


Statement of assets and liabilities—December 31, 2023

Assets:
     
Investments, at value (Cost $207,136,136)
 
$
213,302,161
 
Cash
   
8,094
 
Receivables:
       
Investments sold
   
738,047
 
Dividends and interest
   
1,587,906
 
Other assets
   
25,852
 
Total assets
   
215,662,060
 
         
Liabilities:
       
Payables:
       
Investments purchased
   
1,488,810
 
Advisory
   
180,257
 
Administration
   
33,757
 
Chief Compliance Officer
   
6,093
 
Director
   
10,459
 
Fund accounting
   
711
 
Custody
   
5,995
 
Transfer Agent
   
2,481
 
Legal
   
9,421
 
Audit
   
45,000
 
Reports and notices to shareholders
   
14,774
 
Accrued expenses and other liabilities
   
8
 
Total liabilities
   
1,797,766
 
         
Preferred Stock:
       
2.75% Convertible Preferred Stock – $0.001 par value, $25 liquidation value per share;
       
  2,254,557 shares outstanding
       
Total preferred stock
   
56,363,925
 
         
Net assets applicable to common shareholders
 
$
157,500,369
 
         
Net assets applicable to common shareholders:
       
Common stock – $0.001 par value per common share; 199,995,800 shares authorized;
       
  11,010,177 shares issued and outstanding, 14,796,650 shares held in treasury
 
$
397,849,371
 
Cost of shares held in treasury
   
(245,208,216
)
Total distributable earnings (deficit)
   
4,859,214
 
Net assets applicable to common shareholders
 
$
157,500,369
 
Net asset value per common share ($157,500,369 applicable to
       
  11,010,177 common shares outstanding)
 
$
14.30
 

The accompanying notes are an integral part of these financial statements.
15

Special Opportunities Fund, Inc.


Statement of operations

   
For the year ended
 
   
December 31, 2023
 
Investment income:
     
Dividends
 
$
7,486,235
 
Interest
   
2,163,190
 
Total investment income
   
9,649,425
 
         
Expenses:
       
Investment advisory
   
2,097,272
 
Directors’
   
245,943
 
Administration
   
224,336
 
Compliance
   
69,580
 
Reports and notices to shareholders
   
59,916
 
Audit
   
44,995
 
Transfer agency
   
43,840
 
Custody
   
40,222
 
Legal
   
36,828
 
Stock exchange listing
   
32,273
 
Insurance
   
30,908
 
Accounting
   
4,833
 
Other
   
38,773
 
Net expenses
   
2,969,719
 
Net investment income
   
6,679,706
 
         
Net realized and unrealized gains (losses) from investment activities:
       
Net realized gain from:
       
Investments
   
1,077,661
 
Foreign currency translations
   
5,001
 
Distributions received from investment companies
   
1,144,856
 
Net realized gain
   
2,227,518
 
Change in net unrealized appreciation (depreciation) on:
       
Investments
   
17,743,241
 
Foreign currency translations
   
8,730
 
Net realized and unrealized gains from investment activities
   
19,979,489
 
Discount on redemption and repurchase of preferred shares
   
179,207
 
Increase in net assets resulting from operations
   
26,838,402
 
Distributions to preferred stockholders
   
(1,587,197
)
Net increase in net assets applicable to common shareholders resulting from operations
 
$
25,251,205
 

The accompanying notes are an integral part of these financial statements.
16

Special Opportunities Fund, Inc.


Statement of cash flows

   
For the Year Ended
 
   
December 31, 2023
 
Cash flows from operating activities:
     
Net increase in net assets
 
$
26,838,402
 
Adjustments to reconcile net increase in net assets applicable to common
       
   shareholders resulting from operations to net cash provided by operating activities:
       
Purchases of investments
   
(127,141,189
)
Proceeds from sales of investments
   
138,497,698
 
Net purchases and sales of short-term investments
   
(3,171,952
)
Return of capital and capital gain distributions received from underlying investments
   
3,937,263
 
Accretion of discount
   
149
 
Increase in dividends and interest receivable
   
(815,874
)
Decrease in receivable for investments sold
   
379,838
 
Increase in other assets
   
(1,045
)
Decrease in payable for investments purchased
   
(880,148
)
Increase in payable to Adviser
   
192
 
Decrease in accrued expenses and other liabilities
   
(22,501
)
Net distributions received from investment companies
   
1,144,856
 
Net realized gain from investments
   
(2,222,518
)
Litigation and other proceeds
   
40,372
 
Discount on redemption and repurchase of preferrd shares
    (179,207
)
Net change in unrealized appreciation of investments
   
(17,743,241
)
Net cash provided by operating activities
   
18,661,095
 
         
Cash flows from financing activities:
       
Distributions paid to common shareholders
   
(11,783,156
)
Distributions paid to preferred shareholders
   
(1,587,197
)
Repurchase of common stock
   
(5,077,215
)
Repurchase of preferred stock
   
(1,830,718
)
Net cash used in financing activities
   
(20,278,286
)
Net change in cash
 
$
(1,617,191
)
         
Cash:
       
Beginning of year
   
1,625,285
 
End of year
 
$
8,094
 

The accompanying notes are an integral part of these financial statements.
17

Special Opportunities Fund, Inc.

Statements of changes in net assets applicable to common shareholders

   
For the
   
For the
 
   
year ended
   
year ended
 
   
December 31, 2023
   
December 31, 2022
 
From operations:
           
Net investment income
 
$
6,679,706
   
$
3,478,374
 
Net realized gain (loss) from:
               
Investments
   
1,077,661
     
(954,692
)
Foreign currency translations
   
5,001
     
 
Distributions received from investment companies
   
1,144,856
     
1,828,305
 
Net change in unrealized appreciation (depreciation) on:
               
Investments
   
17,743,241
     
(29,012,831
)
Foreign currency translations
   
8,730
     
 
Discount on redemption and repurchases of preferred shares
   
179,207
     
 
Net increase (decrease) in net assets resulting from operations
   
26,838,402
     
(24,660,844
)
                 
Distributions paid to preferred shareholders:
               
Net dividends and distributions
   
(1,587,197
)
   
(1,467,040
)
Total dividends and distributions paid to preferred shareholders
   
(1,587,197
)
   
(1,467,040
)
Net increase (decrease) in net assets applicable to common
               
  shareholders resulting from operations
   
25,251,205
     
(26,127,884
)
                 
Distributions paid to common shareholders:
               
Net dividends and distributions
   
(6,271,117
)
   
(15,317,585
)
Return of capital
   
(5,512,039
)
   
(226,028
)
Total dividends and distributions paid to common shareholders
   
(11,783,156
)
   
(15,543,613
)
                 
Capital Stock Transactions (Note 4)
               
Repurchase of common stock through tender offer
   
     
(19,612,500
)
Repurchase of common stock
   
(5,077,215
)
   
 
Total capital stock transactions
   
(5,077,215
)
   
(19,612,500
)
Net increase (decrease) in net assets
               
  applicable to common shareholders
   
8,390,834
     
(61,283,997
)
                 
Net assets applicable to common shareholders:
               
Beginning of year
   
149,109,535
     
210,393,532
 
End of year
 
$
157,500,369
   
$
149,109,535
 

The accompanying notes are an integral part of these financial statements.
18

Special Opportunities Fund, Inc.









(This Page Intentionally Left Blank.)








 

 
19

Special Opportunities Fund, Inc.


Financial highlights

Selected data for a share of common stock outstanding throughout each year is presented below:
 

Net asset value, beginning of year
Net investment income (loss)(1)
Net realized and unrealized gains (losses) from investment activities
Total from investment operations
Common share equivalent of dividends paid to preferred shareholders from:
Net investment income
Net realized gains from investment activities
Net increase (decrease) in net assets attributable to common stockholders resulting form operations
Dividends and distributions paid to common shareholders from:
Net investment income
Net realized gains from investment activities
Return of capital
Total dividends and distributions paid to common shareholders
Anti-Dilutive effect of Common Share Repurchase
Dilutive effect of conversions of preferred shares to common shares
Anti-Dilutive effect of tender offer
Net asset value, end of year
Market value, end of year
Total net asset value return(2)
Total market price return(3)
Ratio to average net assets attributable to common shares:
Ratio of expenses to average assets(4)
Ratio of net investment income to average net assets(1)
Supplemental data:
Net assets applicable to common shareholders, end of year/period (000’s)
Liquidation value of preferred stock (000’s)
Portfolio turnover
Preferred Stock:
Total Shares Outstanding
Asset coverage per share of preferred shares, end of year
 

The accompanying notes are an integral part of these financial statements.

20

Special Opportunities Fund, Inc.


Financial highlights (continued)

For the year ended December 31,
 
2023
   
2022
   
2021
   
2020
   
2019
 
$
13.01
   
$
16.55
   
$
16.13
   
$
16.06
   
$
13.78
 
 
0.58
     
0.28
     
0.18
     
0.59
     
0.31
 
 
1.80
     
(2.43
)
   
4.06
     
0.84
     
3.13
 
 
2.38
     
(2.15
)
   
4.24
     
1.43
     
3.44
 
                                     
 
(0.14
)
   
(0.03
)
   
(0.05
)
   
(0.21
)
   
(0.05
)
 
     
(0.09
)
   
(0.03
)
   
(0.02
)
   
(0.18
)
 
2.24
     
(2.27
)
   
4.16
     
1.20
     
3.21
 
                                     
 
(0.55
)
   
(0.34
)
   
(0.23
)
   
(0.65
)
   
(0.20
)
 
     
(0.96
)
   
(1.57
)
   
(0.48
)
   
(0.73
)
 
(0.49
)
   
(0.02
)
   
     
     
 
 
(1.04
)
   
(1.32
)
   
(1.80
)
   
(1.13
)
   
(0.93
)
 
0.09
     
     
     
     
 
 
     
     
(1.94
)
   
     
 
 
     
0.05
     
     
     
 
$
14.30
   
$
13.01
   
$
16.55
   
$
16.13
   
$
16.06
 
$
11.86
   
$
11.40
   
$
15.45
   
$
14.08
   
$
14.73
 
 
18.74
%
   
-13.81
%
   
14.09
%
   
9.24
%
   
23.72
%
 
14.13
%
   
-18.33
%
   
23.62
%
   
5.00
%
   
32.93
%
                                     
 
1.95
%
   
1.89
%
   
1.57
%
   
2.13
%
   
1.99
%
 
4.40
%
   
2.03
%
   
0.72
%
   
1.96
%
   
2.01
%
                                     
$
157,500
   
$
149,110
   
$
210,394
   
$
137,129
   
$
136,504
 
$
56,364
   
$
58,374
   
$
   
$
55,599
   
$
55,599
 
 
64
%
   
54
%
   
80
%
   
85
%
   
75
%
                                     
 
2,254,557
     
2,334,954
     
     
2,223,976
     
2,223,976
 
$
95
   
$
89
   
$
   
$
87
   
$
86
 

The accompanying notes are an integral part of these financial statements.
21

Special Opportunities Fund, Inc.


Financial highlights (continued)

(1)
Recognition of investment income by the Fund is affected by the timing and declaration of dividends by the underlying investment companies in which the Fund invests.
(2)
Total net asset value return is calculated assuming a $10,000 purchase of common stock at the current net asset value on the first day of each period reported and a sale at the current net asset value on the last day of each period reported, and assuming reinvestment of dividends and other distributions at the net asset value on the ex-dividend date. Total investment return based on net asset value is hypothetical as investors can not purchase or sell Fund shares at net asset value but only at market prices. Returns do not reflect the deduction of taxes that a shareholder could pay on Fund dividends and other distributions, if any, or the sale of Fund shares.
(3)
Total market price return is calculated assuming a $10,000 purchase of common stock at the current market price on the first day of each period reported and a sale at the current market price on the last day of each period reported, and assuming reinvestment of dividends and other distributions to common shareholders at the lower of the NAV or the closing market price on the ex-dividend date. Total investment return does not reflect brokerage commissions and has not been annualized for the period of less than one year. Returns do not reflect the deduction of taxes that a shareholder could pay on Fund dividends and other distributions, if any, or the sale of Fund shares.
(4)
Does not include expenses of the investment companies in which the Fund invests.



The accompanying notes are an integral part of these financial statements.
22

Special Opportunities Fund, Inc.


Notes to financial statements

Note 1
Organization and significant accounting policies
Special Opportunities Fund, Inc. (formerly, Insured Municipal Income Fund Inc.) (the “Fund”) was incorporated in Maryland on February 18, 1993, and is registered with the United States Securities and Exchange Commission (“SEC”) under the Investment Company Act of 1940, as amended (“1940 Act”), as a closed-end diversified management investment company.  Effective December 21, 2009, the Fund changed its name to the Special Opportunities Fund, Inc. and changed its investment objective to total return.  There can be no assurance that the Fund’s investment objective will be achieved.  The Fund’s previous investment objective was to achieve a high level of current income that was exempt from federal income tax, consistent with the preservation of capital.
 
The Fund is an investment company and accordingly follows the investment company accounting and reporting guidance of the Financial Accounting Standards Board (FASB) Accounting Standard Codification Topic 946 “Financial Services—Investment Companies”.
 
In the normal course of business, the Fund may enter into contracts that contain a variety of representations or that provide indemnification for certain liabilities.  The Fund’s maximum exposure under these arrangements is unknown, as this would involve future claims that may be made against the Fund that have not yet occurred.  However, the Fund has not had prior claims or losses pursuant to these contracts and expects the risk of loss to be remote.
 
The preparation of financial statements in accordance with Accounting Principles Generally Accepted in the United States of America requires the Fund’s management to make estimates and assumptions that affect the reported amounts and disclosures in the financial statements.  Actual results could differ from those estimates.  The following is a summary of significant accounting policies:
 
Valuation of investments—The Fund calculates its net asset value based on the current market value for its portfolio securities.  The Fund obtains market values for its securities from independent pricing sources and broker-dealers.  Independent pricing sources may use last reported sale prices or if not available the most recent bid price, current market quotations or valuations from computerized “matrix” systems that derive values based on comparable securities.  A matrix system incorporates parameters such as security quality, maturity and coupon, and/or research and evaluations by its staff, including review of broker-dealer market price quotations, if available, in determining the valuation of the portfolio securities.  If a market value is not available from an independent pricing source or a broker-dealer for a particular security, that security is valued at fair value as determined in good faith by or under the direction of the Fund’s Board of Directors (the “Board”).  Various factors may be
 
23

Special Opportunities Fund, Inc.


Notes to financial statements

reviewed in order to make a good faith determination of a security’s fair value.  The purchase price, or cost, of these securities is arrived at through an arms length transaction between a willing buyer and seller in the secondary market and is indicative of the value on the secondary market.  Current transactions in similar securities in the marketplace are evaluated.  Factors for other securities may include, but are not limited to, the type and cost of the security; contractual or legal restrictions on resale of the security; relevant financial or business developments of the issuer; actively traded similar or related securities; conversion or exchange rights on the security; related corporate actions; and changes in overall market conditions.  If events occur that materially affect the value of securities between the close of trading in those securities and the close of regular trading on the New York Stock Exchange, the securities may be fair valued.  U.S. and foreign debt securities including short-term debt instruments having a maturity of 60 days or less shall be valued in accordance with the price supplied by a Pricing Service using the evaluated bid price.  Money market mutual funds, demand notes and repurchase agreements are valued at cost.  If cost does not represent current market value the securities will be priced at fair value as determined in good faith by or under the direction of the Fund’s Board.
 
The Fund has adopted fair valuation accounting standards that establish an authoritative definition of fair value and set out a hierarchy for measuring fair value.  These standards require additional disclosures about the various input and valuation techniques used in measuring fair value.  Fair value inputs are summarized in the three broad levels listed below:
 
Level 1—
Unadjusted quoted prices in active markets for identical assets or liabilities that the Fund has the ability to access.
   
Level 2—
Observable inputs other than quoted prices included in Level 1 that are observable for the asset or liability, either directly or indirectly.  These inputs may include quoted prices for the identical instrument on an inactive market, prices for similar instruments, interest rates, prepayment speeds, credit risk, yield curves, default rates and similar data.
   
Level 3—
Unobservable inputs for the asset or liability, to the extent relevant observable inputs are not available, representing the Fund’s own assumptions about the assumptions a market participant would use in valuing the asset or liability, and would be based on the best information available.

The availability of observable inputs can vary from security to security and is affected by a wide variety of factors, including, for example, the type of security, whether the security is new and not yet established in the marketplace, the liquidity of markets, and other characteristics particular to the security.  To the
 

24

Special Opportunities Fund, Inc.
 

Notes to financial statements

extent that valuation is based on models or inputs that are less observable or unobservable in the market, the determination of fair value requires more judgment.  Accordingly, the degree of judgment exercised in determining fair value is greatest for instruments categorized in Level 3.
 
The inputs used to measure fair value may fall into different levels of the fair value hierarchy.  In such cases, for disclosure purposes, the level in the fair value hierarchy within which the fair value measurement falls in its entirety, is determined based on the lowest level input that is significant to the fair value measurement in its entirety.
 
The significant unobservable inputs used in the fair value measurement of the Fund’s Level 3 investments are listed in the table on page 30.  Significant changes in any of these inputs in isolation may result in a change in fair value measurement.
 
In accordance with procedures established by the Fund’s Board of Directors, the Adviser shall initially value non-publicly-traded securities (for which a current market value is not readily available) at their acquisition cost less related expenses, where identifiable, unless and until the Adviser determines that such value does not represent fair value.
 
The Adviser sends a memorandum to the Chairman of the Valuation Committee with respect to any non-publicly-traded positions that are valued using a method other than acquisition cost detailing the reason, factors considered, and impact on the Fund’s NAV.  If the Chairman determines that such fair valuation(s) require the involvement of the Valuation Committee, a special meeting of the Valuation Committee is called as soon as practicable to discuss such fair valuation(s).  The Valuation Committee of the Board consists of at least two non-interested Directors, as defined by the 1940 Act.
 
In addition to special meetings, the Valuation Committee meets prior to each regular quarterly Board meeting.  At each quarterly meeting, the Adviser delivers a written report (the “Quarterly Report”) regarding any recommendations of fair valuation during the past quarter, including fair valuations which have not changed.  The Valuation Committee reviews the Quarterly Report, discusses the valuation of the fair valued securities with appropriate levels of representatives from the Adviser’s management, and, unless more information is required, approves the valuation of fair valued securities.
 
The Valuation Committee also reviews other interim reports as necessary and, pursuant to Rule 2a-5 under the 1940 Act, periodically assesses any material risks associated with the determination of fair value of Fund investments.
 

25

Special Opportunities Fund, Inc.


Notes to financial statements

The following is a summary of the fair valuations according to the inputs used as of December 31, 2023 in valuing the Fund’s investments:
 
   
Quoted Prices in
                   
   
Active Markets
                   
   
for Identical
   
Significant Other
   
Unobservable
       
   
Investments
   
Observable Inputs
   
Inputs
       
   
(Level 1)
   
(Level 2)
   
(Level 3)*
   
Total
 
Investment Companies
                       
Closed-End Funds
 
$
129,796,963
   
$
   
$
   
$
129,796,963
 
Business Development
                               
  Companies
   
22,596,515
     
     
     
22,596,515
 
Special Purpose
                               
  Acquisition Vehicles
   
25,287,187
     
6,277,254
     
     
31,564,441
 
Preferred Stocks
                               
Real Estate Investment Trusts
   
345,678
     
     
     
345,678
 
Other Common Stocks
                               
Biotechnology
   
608,000
     
     
     
608,000
 
Financial Services
   
253,240
     
     
     
253,240
 
Food Products
   
412,600
     
     
     
412,600
 
Oil, Gas & Consumable Fuels
   
6,918,780
     
     
     
6,918,780
 
Real Estate Management
                               
  & Development
   
1,051,214
     
     
     
1,051,214
 
Trusts
   
1,527,009
     
     
0
     
1,527,009
 
Real Estate Investment Trusts
   
1,414,054
     
     
     
1,414,054
 
Corporate Obligations
   
     
     
1,598,381
     
1,598,381
 
Unsecured Notes
   
4,792,252
     
     
0
     
4,792,252
 
Warrants
   
83,051
     
35,736
     
0
     
118,787
 
Rights
   
35,706
     
13,460
     
     
49,166
 
Money Market Funds
   
10,255,081
     
     
     
10,255,081
 
Total
 
$
205,377,330
   
$
6,326,450
   
$
1,598,381
   
$
213,302,161
 

*
The Fund measures Level 3 activity as of the beginning and end of each financial reporting period.

The fair value of derivative instruments as reported within the Schedule of Investments as of December 31, 2023:
 
Derivatives not accounted
Statement of Assets &
 
for as hedging instruments
Liabilities Location
Value
Equity Contracts – Warrants
Investments, at value
$118,787


26

Special Opportunities Fund, Inc.


Notes to financial statements

The effect of derivative instruments on the Statement of Operations for the year ended December 31, 2023:
 
 
Amount of Realized Loss on Derivatives Recognized in Income
Derivatives not accounted
Statement of
 
for as hedging instruments
Operations Location
Value
Equity Contracts – Warrants
Net Realized Loss
$(1,166,220)

on Investments
 

 
Change in Unrealized Appreciation on Derivatives Recognized in Income
Derivatives not accounted
Statement of
 
for as hedging instruments
Operations Location
Total
Equity Contracts – Warrants
Net change in unrealized
$957,340

appreciation of investments
 

The average monthly share amount of warrants during the period was 3,040,117. The average monthly market value of warrants during the period was $199,424.
 
Level 3 Reconciliation Disclosure
The following is a reconciliation of Level 3 assets for which significant unobservable inputs were used to determine fair value:
 
   
Trust
   
Corporate
   
Unsecured
       
Category
 
Certificates
   
Obligations
   
Notes
   
Warrants
 
Balance as of 12/31/2022
 
$
18,279
   
$
1,525,819
   
$
   
$
4,639
 
Acquisitions
   
     
882,319
     
     
 
Dispositions
   
     
     

   
 
Transfers into (out of) Level 3
   
     
     
0
     
(252
)
Accretion/Amortization
   
     
(149
)
   
     
 
Corporate Actions
   
     
     
     
 
Realized Gain (Loss)
   
     
     

   
 
Change in unrealized appreciation (depreciation)
   
(18,279
)
   
(809,608
)
   
     
(4,387
)
Balance as of 12/31/2023
 
$
0
   
$
1,598,381
   
$
0
   
$
0
 
Change in unrealized appreciation (depreciation)
                               
  during the period for Level 3 investments
                               
  held at December 31, 2023
 
$
(18,279
)
 
$
(809,608
)
 
$
   
$
(4,568
)


27

Special Opportunities Fund, Inc.


Notes to financial statements

The following table presents additional information about valuation methodologies and inputs used for investments that are measured at fair value and categorized within Level 3 as of December 31, 2023:
 
   
Fair Value
 
Valuation
Unobservable
 
Impact to valuation
Category
 
12/31/2023
 
Methodologies
Inputs
Range
from an increase to input
Trust
 
$
0
 
Market Approach
Last traded price,
$0.00-
Increase
  Certificates
          
Company-Specific
0.057

            Information
 

Corporate
   
1,598,381
 
Market Approach
Last traded price,
4.00-
Increase
  Obligations
       

Company-Specific
51.90

         

Information
 

Unsecured
   
0
 
Market Approach
Company-Specific
0.00-
Increase
  Notes
       

Information
11.40

Warrants
   
0
 
Market Approach
Company-Specific
0.00-
Increase
             
Information
0.10


Note 2
Related party transactions
Bulldog Investors, LLP serves as the Fund’s Investment Adviser (the “Investment Adviser”) under the terms of the Investment Advisory Agreement effective October 10, 2009.  Effective May 7, 2013 Brooklyn Capital Management, LLC changed its name to Bulldog Investors, LLP.  In accordance with the investment advisory agreement, the Fund is obligated to pay the Investment Adviser a monthly investment advisory fee at an annual rate of 1.00% of the Fund’s average weekly total assets.

Effective January 1, 2023, the Fund pays each of its directors who is not a director, officer or employee of the Investment Adviser, the Administrator or any affiliate thereof an annual fee of $55,000, quarterly plus $5,000 for each special in-person meeting (or $500 if attended by telephone) of the board of directors and $500 for special committee meetings held in between regularly scheduled Board meetings.  As additional annual compensation, the Audit Committee Chairman, Corporate Governance Committee Chairman and Valuation Committee Chairman receive $5,000. Effective January 1, 2023, the Fund’s Chief Compliance Officer (“CCO”) receives annual compensation in the amount of $62,000.  In addition, the Fund reimburses the directors and CCO for travel and out-of-pocket expenses incurred in connection with Board of Directors’ meetings and CCO due diligence requirements.
 
U.S. Bank Global Fund Services (“Fund Services”), an indirect wholly-owned subsidiary of U.S. Bancorp, serves as the Fund’s Administrator (the “Administrator”) and, in that capacity, performs various administrative services for the Fund.  Fund Services also serves as the Fund’s Fund Accountant (the “Fund Accountant”).  U.S.
 

28

Special Opportunities Fund, Inc.


Notes to financial statements

Bank, N.A. serves as the Fund’s custodian (the “Custodian”).  The Custodian is an affiliate of the Administrator.  The Administrator prepares various federal and state regulatory filings, reports and returns for the Fund; prepares reports and materials to be supplied to the directors, monitors the activities of the Custodian and Fund Accountant; coordinates the preparation and payment of the Fund’s expenses and reviews the Fund’s expense accruals.  Equiniti Trust Company, LLC serves as the Fund’s Transfer Agent.
 
Note 3
Convertible Preferred Stock
During the year ended December 31, 2021 the Fund converted 2,163,053 shares or $54,076,325 of the Fund’s Convertible Preferred Stock, Series B into 4,211,996 shares of the Fund’s common stock.  The remaining 60,923 of Convertible Preferred Shares were redeemed at $25 per share for a total of $1,523,075.
 
On January 21, 2022 the Fund completed its Convertible Preferred Rights offering at $25 per share. As a result of this offering the Fund raised $58,373,850 and issued 2,334,954 shares of 2.75% Convertible Preferred Stock, Series C. The holders of Convertible Preferred Stock, Series C may convert their shares to common stock on a quarterly basis at a conversion rate equivalent to the current conversion price of $18.250 per share of common stock (which is a current ratio of 1.3699 shares of common stock for each share of Convertible Preferred Stock, Series C held). The conversion price (and resulting conversion ratio) will be adjusted for any distributions made to or on behalf of common stockholders. Following any such conversion, shares of common stock shall be issued as soon as reasonably practicable following the next quarterly dividend payment date. Until the mandatory redemption date of the Convertible Preferred Stock, Series C, January 21, 2027, at any time following the second anniversary of the expiration date of the Convertible Preferred Stock, Series C rights offering, the Board may, in its sole discretion, redeem all or any part of the then outstanding shares of Convertible Preferred Stock, Series C at $25.00 per share. Under such circumstances, the Fund shall provide no less than 30 days’ notice to the holders of Convertible Preferred Stock, Series C that, unless such shares have been converted by a certain date, the shares will be redeemed. If, at any time from and after the date of issuance of the Convertible Preferred Stock, Series C, the market price of the common stock is equal to or greater than $21.50 per share (as adjusted for dividends or other distributions made to or on behalf of holders of the common stock), the Board may, in its sole discretion, require the holders of the Convertible Preferred Stock, Series C to convert all or any part of their shares into shares of common stock at a conversion rate equivalent to the current conversion price of $18.250 per share of common stock (which is a current ratio of 1.3699 shares of common stock for each share of Convertible Preferred Stock, Series C held), subject to adjustment upon the occurrence of certain events.
 


29

Special Opportunities Fund, Inc.


Notes to financial statements

During the year ended December 31, 2023, the Fund purchased 80,397 shares of preferred stock in the open market at a cost of $1,830,718. The weighted average discount of these purchases comparing the average purchase price to liquidation value at the close of the New York Stock Exchange was 8.95%.
 
The conversion price (and resulting conversion ratio) will be adjusted for any dividends or other distributions made to or on behalf of common stockholders. Notice of such mandatory conversion shall be provided by the Fund in accordance with its Articles of Incorporation. In connection with all conversions shareholders of Convertible Preferred Stock would receive payment for all declared and unpaid dividends on the shares of Convertible Preferred Stock held to the date of conversion, but after conversion would no longer be entitled to the dividends, liquidation preference or other rights attributable to holders of the Convertible Preferred Stock. The Convertible Preferred Stock is classified outside of the permanent equity (net assets applicable to Common Stockholders) in the accompanying financial statements in accordance with accounting for redeemable equity instruments, which requires preferred securities that are redeemable for cash or other assets to be classified outside of permanent equity to the extent that the redemption is at a fixed or determinable price and at the option of the holder or upon occurrence of an event that is not solely within the control of the issuer. The Fund is required to meet certain asset coverage tests with respect to the Convertible Preferred Stock as required by the 1940 Act. In addition, pursuant to the Rating Agency Guidelines established by Moody’s, the Fund is required to maintain a certain discounted asset coverage. If the Fund fails to meet these requirements and does not correct such failure, the Fund may be required to redeem, in part or in full, the Convertible Preferred Stock at a redemption price of $25.00 per share, plus an amount equal to the accumulated and unpaid dividends, whether or not declared on such shares, in order to meet these requirements. Additionally, failure to meet the foregoing asset coverage requirements could restrict the Fund’s ability to pay dividends to Common Stockholders and could lead to sales of portfolio securities at inopportune times. The Fund has met these requirements since issuing the Convertible Preferred Stock.
 
Note 4
Purchases and sales of securities
For the year ended December 31, 2023, aggregate purchases and sales of portfolio securities, excluding short-term securities, were $127,141,189 and $138,497,698, respectively.  The Fund did not purchase or sell U.S. government securities during the year ended December 31, 2023.
 
30

Special Opportunities Fund, Inc.


Notes to financial statements
 
Note 5
Capital share transactions
During the year ended December 31, 2023, the Fund purchased 452,787 shares of common stock in the open market at a cost of $5,077,215. The weighted average discount of these purchases comparing the average purchase price to net asset value at the close of the New York Stock Exchange was 17.02%.
 
During the years ended December 31, 2022, 2021, 2020, 2019 and 2018 there were no shares of common stock repurchased by the Fund.
 
The Fund completed an offering to purchase up to 1,250,000 of the Fund’s shares outstanding at 97% of the net asset value (“NAV”) per common share on April 1, 2022. At the expiration of the offer on April 1, 2022, a total of 7,549,920 shares or approximately 59.39% of the Fund’s outstanding common shares were validly tendered. As the total number of common shares tendered exceeded 1,250,000 common shares, approximately 16.56% of the shares tendered by each tendering shareholder were accepted for payment at a price of $15.69 per share (97% of the NAV per common share of $16.18).
 
During the year ended December 31, 2021 the Fund converted 2,163,053 shares of 3.50% Convertible Preferred Stock into 4,211,996 shares of Common Stock.
 
Note 6
Federal tax status
The Fund has elected to be taxed as a “regulated investment company” and intends to distribute substantially all taxable income to its shareholders and otherwise comply with the provisions of the Internal Revenue Code applicable to regulated investment companies.  Therefore, no provision for federal income taxes or excise taxes has been made.

In order to avoid imposition of the excise tax applicable to regulated investment companies, the Fund intends to declare each year as dividends in each calendar year at least 98.0% of its net investment income (earned during the calendar year) and 98.2% of its net realized capital gains (earned during the twelve months ended October 31) plus undistributed amounts, if any, from prior years.
 

31

Special Opportunities Fund, Inc.


Notes to financial statements

The tax character of distributions paid to shareholders during the fiscal years ended December 31, 2023 and December 31, 2022 were as follows:
 
   
For the
   
For the
 
   
year ended
   
year ended
 
Distributions paid to common shareholders from:
 
December 31, 2023
   
December 31, 2022
 
Ordinary income
 
$
6,271,117
   
$
4,047,986
 
Long-term capital gains
   
     
11,269,599
 
Return of capital
   
5,512,039
     
226,028
 
Total distributions paid
 
$
11,783,156
   
$
15,543,613
 
                 
   
For the
   
For the
 
   
year ended
   
year ended
 
Distributions paid to preferred shareholders from:
 
December 31, 2023
   
December 31, 2022
 
Ordinary income
 
$
1,587,197
   
$
387,696
 
Long-term capital gains
   
     
1,079,344
 
Total distributions paid
 
$
1,587,197
   
$
1,467,040
 

The Fund designated as long-term capital gain dividends, pursuant to Internal Revenue Code Section 852(b)(3), the amount necessary to reduce the earnings and profits for the Fund related to net capital gains to zero for the year ended December 31, 2023.
 
The following information is presented on an income tax basis as of December 31, 2023:
 
Tax cost of investments
 
$
207,940,261
 
Unrealized appreciation
   
25,436,273
 
Unrealized depreciation
   
(20,065,643
)
Net unrealized depreciation
   
5,370,630
 
Undistributed ordinary income
   
 
Undistributed long-term gains
   
 
Total distributable earnings
   
 
Other accumulated/gains losses and other temporary differences
   
(511,416
)
Total accumulated losses
 
$
4,859,214
 

GAAP requires that certain components of net assets relating to permanent differences be reclassified between financial and tax reporting. These reclassifications have no effect on net assets or net asset value per share. For the fiscal year ended December 31, 2023, there were no reclassifications made between total distributable earnings and paid-in capital.

Net capital losses incurred after October 31, and within the taxable year are deemed to arise on the first business day of the Fund’s next taxable year.  At December 31, 2023, the Fund did not defer any post-October losses.
 
At December 31, 2023, the Fund had $511,416 in long-term capital loss carryovers which have an unlimited carryover period.

32

Special Opportunities Fund, Inc.


Notes to financial statements
 
The Fund recognizes the tax benefits of uncertain tax positions only where the position is “more likely than not” to be sustained assuming examination by tax authorities.  Management has analyzed the Fund’s tax positions, and has concluded that no liability for unrecognized tax benefits should be recorded related to uncertain tax positions taken on returns filed for open tax years (2020-2022), or expected to be taken in the Fund’s 2023 tax returns. The Fund identifies its major tax jurisdictions as U.S. Federal and the State of Maryland; however the Fund is not aware of any tax positions for which it is reasonably possible that the total amounts of unrecognized tax benefits will change materially in the next twelve months.
 
Note 7
Recent Market Events
U.S. and international markets have experienced and may continue to experience significant periods of volatility in recent years and months due to a number of economic, political and global macro factors including rising inflation, uncertainty regarding central banks’ interest rate increases, the possibility of a national or global recession, trade tensions, political events, the war between Russia and Ukraine and the impact of the coronavirus (COVID-19) global pandemic. The global recovery from COVID-19 may last for an extended period of time. As a result of continuing political tensions and armed conflicts, including the war between Ukraine and Russia and general unrest in the Middle East, the U.S. and the European Union imposed sanctions on certain Russian individuals and companies, including certain financial institutions, and have limited certain exports and imports to and from Russia. The war has contributed to recent market volatility and may continue to do so. These developments, as well as other events, could result in further market volatility and negatively affect financial asset prices, the liquidity of certain securities and the normal operations of securities exchanges and other markets, despite government efforts to address market disruptions. Continuing market volatility as a result of recent market conditions or other events may have adverse effects on your account.
 
Note 8
Additional information
Notice is hereby given in accordance with Section 23(c) of the Investment Company Act of 1940 that the Fund may purchase, from time to time, shares of its common stock and its convertible preferred stock in the open market.

Fund directors and officers and advisory persons to the Fund, including insiders and employees of the Fund and of the Fund’s investment adviser, may purchase or sell Fund securities from time to time, subject to the restrictions set forth in the Fund’s Code of Ethics, as amended, a copy of which is available on the Fund’s website. Please see the corporate governance section of the Fund’s website at www.specialopportunitiesfundinc.com.
 

33

Special Opportunities Fund, Inc.


Notes to financial statements

The Fund may seek proxy voting instructions from shareholders regarding certain underlying closed-end funds held by the Fund.  Please see the proxy voting instructions section on the Fund’s website at www.specialopportunitiesfundinc.com for further information.
 
Note 9
Subsequent events
In preparing these financial statements, management has evaluated events and transactions for potential recognition or disclosure resulting from subsequent events through the date the financial statements were available to be issued. Management has determined that there were no subsequent events that would need to be disclosed in the Fund’s financial statements.



 

34

Special Opportunities Fund, Inc.


Report of independent registered public accounting firm

To the Board of Directors and Shareholders of Special Opportunities Fund, Inc.
 
Opinion on the Financial Statements
 
We have audited the accompanying statement of assets and liabilities of Special Opportunities Fund, Inc., including the portfolio of investments, as of December 31, 2023, the related statements of operations and cash flows for the year then ended, the statements of changes in net assets for each of the two years in the period then ended, and financial highlights for each of the five years in the period then ended, and the related notes (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of Special Opportunities Fund, Inc. as of December 31, 2023, the results of its operations and cash flows for the year then ended, the changes in its net assets for each of the two years in the period then ended, and the financial highlights for each of the five years in the period then ended, in conformity with accounting principles generally accepted in the United States of America.
 
Basis for Opinion
 
These financial statements are the responsibility of the Fund’s management. Our responsibility is to express an opinion on the Fund’s financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (“PCAOB”) and are required to be independent with respect to the Fund in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We have served as the Fund’s auditor since 2009.
 
We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. The Fund is not required to have, nor were we engaged to perform, an audit of its internal control over financial reporting. As part of our audits we are required to obtain an understanding of internal control over financial reporting, but not for the purpose of expressing an opinion on the effectiveness of the Fund’s internal control over financial reporting. Accordingly, we express no such opinion.
 
Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. Our procedures included confirmation of securities owned as of December 31, 2023 by correspondence with the custodian and brokers or by other appropriate auditing procedures where replies from brokers were not received. We believe that our audits provide a reasonable basis for our opinion.
 
TAIT, WELLER & BAKER LLP
Philadelphia, Pennsylvania
February 29, 2024
 
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Fund Investment Objective and Policies
 
The Fund investment objective is total return.  The investment objective is not fundamental and may be changed by the Board with 60 days’ notice to stockholders.  To achieve the objective, the Fund invests primarily in securities the Adviser believes have opportunities for appreciation.  The Fund may employ strategies designed to capture price movements generated by anticipated corporate events such as investing in companies involved in special situations, including, but not limited to, mergers, acquisitions, asset sales, spin-offs, balance sheet restructuring, bankruptcy, liquidations and tender offers.  In addition, the Fund may employ strategies designed to invest in the debt, equity, or trade claims of companies in financial distress when the Advisor perceives a mispricing.  Furthermore, the Fund may invest both long and short in related securities or other instruments in an effort to take advantage of perceived discrepancies in the market prices for such securities, including long and short positions in securities involved in an announced merger or acquisition.  Securities which the Adviser identifies include closed-end investment companies with opportunities for appreciation, including funds that trade at a market price discount from their NAV.  In addition to the foregoing, the Adviser seeks out other opportunities in the market that have attractive risk reward characteristics for the Fund.
 
The Fund intends its investment portfolio, under normal market conditions, to consist principally of investments in other closed-end investment companies and the securities of large, mid and small-capitalization companies, including potentially direct and indirect investments in the securities of foreign companies.  Equity securities in which the Fund may invest include common and preferred stocks, convertible securities, warrants and other securities having the characteristics of common stocks, such as ADRs and IDRs, other closed-end investment companies and exchange-traded funds. The Fund may, however, invest a portion of its assets in debt securities or other investment opportunities when the Adviser believes that it is appropriate to do so to earn current income.  For example, when interest rates are high in comparison to anticipated returns on equity investments, the Fund’s investment adviser may determine to invest in debt or preferred securities including bank, corporate or government bonds, notes, and debentures that the Adviser determines are suitable investments for the Fund.  Such determination may be made regardless of the maturity, duration or rating of any such debt security.
 
The Fund may, from time to time, engage in short sales of securities for investment or for hedging purposes.  Short sales are transactions in which the Fund sells a security it does not own.  To complete the transaction, the Fund must borrow the security to make delivery to the buyer.  The Fund is then obligated to replace the security borrowed by purchasing the security at the market price at the time of replacement.  The Fund may sell short individual stocks, baskets of
 

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individual stocks and ETFs that the Fund expects to underperform other stocks which the Fund holds.  For hedging purposes, the Fund may purchase or sell short future contracts on global equity indexes.
 
The Fund may invest, without limitation, in the securities of closed-end funds, provided that, in accordance with Section 12(d)(1)(F) of the 1940 Act, the Fund will limit any such investment to no more than 3% of the voting stock of such fund and will vote such shares as provided in such Section as set forth below.
 
To comply with provisions of the 1940 Act, on any matter upon which stockholders of a closed-end investment company in which the Fund has invested may vote, the Adviser will direct  such shares to be voted in the same proportion as shares held by all other stockholders of such closed-end investment company (i.e., “mirror vote”) or seek instructions from the Fund’s stockholders with regard to the voting on such matter.  If the Adviser deems it appropriate to seek instructions from Fund stockholders, the Adviser will vote such proxies proportionally based upon the total number of shares owned by those shareholders that provide instructions. Fund stockholders are informed of such proxy votes on the Fund’s website and by email, if so requested, and they may provide proxy voting instructions by email.  In a letter dated August 11, 2020 discussing the results of its 2018 compliance examination, the staff of the New York regional office of the SEC’s Office of Compliance Inspections and Examinations opined that, in connection with its prior proxy voting policy, pursuant to which the Fund voted its shares of closed-end funds as determined by a majority of proxy voting instructions received, the Fund “does not in certain cases meet the requirements of the exception set forth in Section 12(d)(1)(E)(iii) of the 1940 Act because in connection with seeking instructions from Fund shareholders with regard to voting certain proxies on behalf of the Fund, the Fund votes such proxies as determined by a majority of the shares owned by those Fund shareholders who provide proxy voting instructions.”  In response thereto, the Fund has amended its proxy voting policy to provide that the Fund will vote such proxies proportionally based upon the total number of shares owned by those shareholders that provide instructions.
 
The ETFs and other closed-end investment companies in which the Fund invests may invest in common stocks and may invest in fixed income securities.  As a stockholder in any investment company, the Fund will bear its ratable share of the investment company’s expenses and would remain subject to payment of the Fund’s advisory and administrative fees with respect to the assets so invested.
 
The Fund’s management utilizes a balanced approach, including “value” and “growth” investing by seeking out companies at reasonable prices, without regard to sector or industry, which demonstrate favorable long-term growth characteristics.  Valuation and growth characteristics may be considered for purposes of selecting potential investment securities.  In general, valuation analysis is used to determine the inherent value of the company by analyzing
 

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Special Opportunities Fund, Inc.


Investment objectives and policies, principal risk factors

financial information such as a company’s price to book, price to sales, return on equity, and return on assets ratios; and growth analysis is used to determine a company’s potential for long-term dividends and earnings growth due to market-oriented factors such as growing market share, the launch of new products or services, the strength of its management and market demand.  Fluctuations in these characteristics may trigger trading decisions to be made by the Fund’s investment adviser with respect to the Fund’s portfolio.
 
Generally, securities will be purchased or sold by the Fund on national securities exchanges and in the over-the-counter market.  From time to time, securities may be purchased or sold in private transactions, including securities that are not publicly traded or that are otherwise illiquid.
 
The Fund may, from time to time, take temporary defensive positions that are inconsistent with the Fund’s principal investment strategies in attempting to respond to adverse market, economic, political or other conditions.  During such times, the Fund may temporarily invest up to 100% of its assets in cash or cash equivalents, including money market instruments, prime commercial paper, repurchase agreements, Treasury bills and other short-term obligations of the U.S. Government, its agencies or instrumentalities.  In these and in other cases, the Fund may not achieve its investment objective.
 
The Fund’s investment adviser may invest the Fund’s cash balances in any investments it deems appropriate, subject to the restrictions set forth in below under “Fundamental Investment Restrictions” and as permitted under the 1940 Act, including investments in repurchase agreements, money market funds, additional repurchase agreements, U.S. Treasury and U.S. agency securities, municipal bonds and bank accounts.  Any income earned from such investments will ordinarily be reinvested by the Fund in accordance with its investment program.  Many of the considerations entering into the Fund’s investment adviser’s recommendations and the portfolio manager’s decisions are subjective.
 
Fundamental Investment Restrictions
 
The following fundamental investment limitations cannot be changed without the affirmative vote of the lesser of (a) more than 50% of the outstanding shares of the Fund or (b) 67% or more of such shares present at a stockholders’ meeting if more than 50% of the outstanding shares are represented at the meeting in person or by proxy.  If a percentage restriction is adhered to at the time of an investment or transaction, a later increase or decrease in percentage resulting from a change in values of portfolio securities or the amount of total assets will not be considered a violation of any of the following limitations or of any of the Fund’s investment policies.  The Fund may not:
 
(1)  issue senior securities (including borrowing money from banks and other entities and thorough reverse repurchase agreements), except (a) the Fund may
 

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borrow in an amount not in excess of 33 1/3% of total assets (including the amount of senior securities issued, but reduced by any liabilities and indebtedness not constituting senior securities), (b) the Fund may issue preferred stock having a liquidation preference in an amount which, combined with the amount of any liabilities or indebtedness constituting senior securities, is not in excess of 50% of its total assets (computed as provided in clause (a) above) and (c) the Fund may borrow up to an additional 5% of its total assets (not including the amount borrowed) for temporary or emergency purposes.
 
The following interpretation applies to, but is not a part of, fundamental limitation:
 
(1)  each state (including the District of Columbia and Puerto Rico), territory and possession of the United States, each political subdivision, agency, instrumentality and authority thereof, and each multi-state agency of which a state is a member is a separate “issuer.”  When the assets and revenues of an agency authority, instrumentality or other political subdivision are separate from the government creating the subdivision and the security is backed only by the assets and revenues of the subdivision, such subdivision would be deemed to be the sole issuer.  Similarly, in the case of an Industrial Development Bond or Private Activity Bond, if that bond is backed only by the assets and revenues of the non-governmental user, then that non-governmental user would be deemed to be the sole issuer.  However, if the creating government or another entity guarantees a security, then to the extent that the value of all securities issued or guaranteed by that government or entity and owned by the Fund exceeds 10% of the Fund’s total assets, the guarantee would be considered a separate security and would be treated as issued by that government or entity.  This restriction does not limit the percentage of the Fund’s assets that may be invested in Municipal Obligations insured by any given insurer.
 
(2)  purchase any security if, as a result of that purchase, 25% or more of the Fund’s total assets would be invested in securities of issuers having their principal business activities in the same industry, except that this limitation does not apply to securities issued or guaranteed by the U.S. government, its agencies or instrumentalities or to municipal securities.
 
(3)  make loans, except through loans of portfolio securities or through repurchase agreements, provided that for purposes of this restriction, the acquisition of bonds, debentures, other debt securities or instruments, or participations or other interests therein and investment in government obligations, commercial paper, certificates of deposit, bankers’ acceptances or similar instruments will not be considered the making of a loan.
 
(4)  engage in the business of underwriting securities of other issuers, except to the extent that the Fund might be considered an underwriter under the federal securities laws in connection with its disposition of portfolio securities.
 

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(5)  purchase or sell real estate, except that investments in securities of issuers that invest in real estate and investments in mortgage-backed securities, mortgage participations or other instruments supported by interests in real estate are not subject to this limitation, and except that the Fund may exercise rights under agreements relating to such securities, including the right to enforce security interests and to hold real estate acquired by reason of such enforcement until that real estate can be liquidated in an orderly manner.
 
(6)  purchase or sell physical commodities unless acquired as a result of owning securities or other instruments, but the Fund may purchase, sell or enter into financial options and futures, forward and spot currency contracts, swap transactions and other financial contracts or derivative instruments.
 
The Fund has no intention to file a voluntary application for relief under federal bankruptcy law or any similar application under state law for so long as the Fund is solvent and does not foresee becoming insolvent.
 
Principal Risks Factors Related to The Fund’s Investments
 
Other Closed-End Investment Company Securities:  The Fund invests in the securities of other closed-end investment companies.  Investing in other closed-end investment companies involves substantially the same risks as investing directly in the underlying instruments, but the total return on such investments at the investment company level may be reduced by the operating expenses and fees of such other closed-end investment companies, including advisory fees.  There can be no assurance that the investment objective of any investment company in which the Fund invests will be achieved.  Closed-end investment companies are subject to the risks of investing in the underlying securities.  The Fund, as a holder of the securities of another closed-end investment company, will bear its pro rata portion of the closed-end investment company’s expenses, including advisory fees.  These expenses are in addition to the direct expenses of the Fund’s own operations.  To the extent the Fund invests a portion of its assets in investment company securities, those assets will be subject to the risks of the purchased investment company’s portfolio securities, and a stockholder in the Fund will bear not only his proportionate share of the expenses of the Fund, but also, indirectly, the expenses of the purchased investment company.  The market price of a closed-end investment company fluctuates and may be either higher or lower than the NAV of such closed-end investment company.
 
In accordance with Section 12(d)(1)(F) of the 1940 Act, the Fund will be limited by provisions of the 1940 Act that limit the amount the Fund, together with its affiliated persons, can invest in other investment companies to 3% of any other investment company’s total outstanding stock.  As a result, the Fund may hold a smaller position in a closed-end investment company than if it were not subject to this restriction.
 

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Special Opportunities Fund, Inc.


Investment objectives and policies, principal risk factors

Special Purpose Acquisition Companies.  The Fund may invest in units, stock, warrants, and other securities of special purpose acquisition companies or similar special purpose entities that pool funds to seek potential acquisition opportunities (“SPACs”). Unless and until an acquisition meeting the SPAC’s requirements is completed, a SPAC generally deposits substantially all of the cash raised in its IPO (less a specified amount  to cover operating expenses) in a bank trust account which is generally invested in U.S. Government securities, money market securities and cash. If an acquisition that meets the requirements for the SPAC is not completed within a pre-established period of time, the invested funds are returned to the entity’s shareholders. In addition, just prior to completion of an acquisition, shareholders of the SPAC can redeem their shares for a pro rata share of the value of the trust account.  Because SPACs have no operating history or ongoing business other than seeking acquisitions, the value of their securities can vary on the perceived likelihood of management to identify and complete a profitable acquisition. In addition, such securities are subject to secondary market risk and may decline in value if sold prior to deal completion or trust liquidation. However, until a SPAC is liquidated or completes an acquisition, its common stock is unlikely to fall substantially below the per share value of the trust account.  If an acquisition is completed, the former SPAC’s shares and other securities will take on the same risks as an equivalent investment in the acquired company.  Some SPACs may pursue acquisitions only within certain industries or regions, which may increase the volatility of their prices.
 
Short sales.  The Fund is authorized to make short sales. The Fund effects a short sale by borrowing and selling a security it does not own in anticipation of a decline in the value of the security or to hedge against the decline of a security the Fund owns. Short sales carry risks of loss if the price of the security sold short increases after the short sale. As collateral for its short positions, the Fund is required under the 1940 Act to maintain segregated assets consisting of cash, cash equivalents, or liquid securities. The amount of segregated assets is required to be adjusted daily to the extent additional collateral is required based on the change in fair value of the securities sold short.
 
Common Stocks.  The Fund invests in common stocks.  Common stocks represent an ownership interest in a company.  The Fund may also invest in securities that can be exercised for or converted into common stocks (such as convertible preferred stock).  Common stocks and similar equity securities are more volatile and riskier than some other forms of investment.  Therefore, the value of your investment in the Fund may sometimes decrease instead of increase.  Common stock prices fluctuate for many reasons, including adverse events such as unfavorable earnings reports, changes in investors’ perceptions of the financial condition of an issuer, the general condition of the relevant stock market or when political or economic events affecting the issuers occur.  In addition, common stock prices may be sensitive to rising interest rates, as the costs of capital rise and borrowing costs increase for issuers.  Because convertible securities can be
 

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Investment objectives and policies, principal risk factors

converted into equity securities, their values will normally increase or decrease as the values of the underlying equity securities increase or decrease.  The common stocks in which the Fund invests are structurally subordinated to preferred securities, bonds and other debt instruments in a company’s capital structure in terms of priority to corporate income and assets and, therefore, will be subject to greater risk than the preferred securities or debt instruments of such issuers.
 
Exchange Traded Funds.  The Fund may invest in exchange-traded funds, which are investment companies that, in general, aim to track or replicate a desired index, such as a sector, market or global segment.  ETFs are passively or, to a lesser extent, actively managed and their shares are traded on a national exchange.  ETFs do not sell individual shares directly to investors and only issue their shares in large blocks known as “creation units.”  The investor purchasing a creation unit may sell the individual shares on a secondary market.  Therefore, the liquidity of ETFs depends on the adequacy of the secondary market.  There can be no assurance that an ETF’s investment objective will be achieved, as ETFs based on an index may not replicate and maintain exactly the composition and relative weightings of securities in the index. ETFs are subject to the risks of investing in the underlying securities.  The Fund, as a holder of the securities of the ETF, will bear its pro rata portion of the ETF’s expenses, including advisory fees.  These expenses are in addition to the direct expenses of the Fund’s own operations. 
 
Fixed Income Securities, including Non-Investment Grade Securities.  The Fund may invest in fixed income securities, also referred to as debt securities.  Fixed income securities are subject to credit risk and market risk.  Credit risk is the risk of the issuer’s inability to meet its principal and interest payment obligations.  Market risk is the risk of price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity.  There is no limitation on the maturities or duration of fixed income securities in which the Fund invests. Securities having longer maturities generally involve greater risk of fluctuations in value resulting from changes in interest rates.  The Fund’s credit quality policy with respect to investments in fixed income securities does not require the Fund to dispose of any debt securities owned in the event that such security’s rating declines to below investment grade, commonly referred to as “junk bonds.”  Although lower quality debt typically pays a higher yield, such investments involve substantial risk of loss.  Junk bonds are considered predominantly speculative with respect to the issuer’s ability to pay interest and principal and are susceptible to default or decline in market value due to adverse economic and business developments.  The market values for junk bonds tend to be very volatile and those securities are less liquid than investment grade debt securities.  Moreover, junk bonds pose a greater risk that exercise of any of their redemption or call provisions in a declining market may result in their replacement by lower-yielding bonds.  In addition, bonds in the lowest two investment grade categories, despite being of higher credit rating than junk bonds, have speculative characteristics with respect to the issuer’s ability to pay interest and principal and their susceptibility to default or decline in market value.
 

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Special Opportunities Fund, Inc.


Investment objectives and policies, principal risk factors

Corporate Bonds, Government Debt Securities and Other Debt Securities:  The Fund may invest in corporate bonds, debentures and other debt securities.  Debt securities in which the Fund may invest may pay fixed or variable rates of interest. Bonds and other debt securities generally are issued by corporations and other issuers to borrow money from investors.  The issuer pays the investor a fixed or variable rate of interest and normally must repay the amount borrowed on or before maturity.  Certain debt securities are “perpetual” in that they have no maturity date.
 
The Fund may invest in government debt securities, including those of emerging market issuers or of other non-U.S. issuers.  These securities may be U.S. dollar-denominated or non-U.S. dollar-denominated and include: (a) debt obligations issued or guaranteed by foreign national, provincial, state, municipal or other governments with taxing authority or by their agencies or instrumentalities; and (b) debt obligations of supranational entities.  Government debt securities include: debt securities issued or guaranteed by governments, government agencies or instrumentalities and political subdivisions; debt securities issued by government owned, controlled or sponsored entities; interests in entities organized and operated for the purpose of restructuring the investment characteristics issued by the above noted issuers; or debt securities issued by supranational entities such as the World Bank or the European Union.  The Fund may also invest in securities denominated in currencies of emerging market countries.  Emerging market debt securities generally are rated in the lower rating categories of recognized credit rating agencies or are unrated and considered to be of comparable quality to lower rated debt securities.  A non-U.S. issuer of debt or the non-U.S. governmental authorities that control the repayment of the debt may be unable or unwilling to repay principal or interest when due, and the Fund may have limited resources in the event of a default.  Some of these risks do not apply to issuers in large, more developed countries.  These risks are more pronounced in investments in issuers in emerging markets or if the Fund invests significantly in one country.
 
Short Sale Risk:  When a cash dividend is declared on a security in which the Fund holds a short position, the Fund incurs the obligation to pay an amount equal to that dividend to the lender of the shorted security.
 
Depending on arrangements made with the broker-dealer from which it borrowed the security regarding payment over of any payments received by the Fund on such security, the Fund may not receive any payments (including interest) on its collateral deposited with such broker-dealer.
 
Although the Fund’s gain is limited to the price at which it sold the security short, its potential loss is unlimited.
 

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Special Opportunities Fund, Inc.


Investment objectives and policies, principal risk factors

Purchasing securities to close out the short position can itself cause the price of the securities to rise further, thereby exacerbating a possible loss.  Short selling exposes the Fund to unlimited risk with respect to that security due to the lack of an upper limit on the price to which an instrument can rise.
 
The requirements of the 1940 Act and Internal Revenue Code of 1986, as amended (the “Code”) provide that the Fund not make a short sale if, after giving effect to such sale, the market value of all securities sold short by the Fund exceeds 30% of the value of its managed assets.
 
Small and Medium Cap Company Risk:  Compared to investment companies that focus only on large capitalization companies, the Fund’s share price may be more volatile because it also invests in small and medium capitalization companies.  Compared to large companies, small and medium capitalization companies are more likely to have (i) more limited product lines or markets and less mature businesses, (ii) fewer capital resources, (iii) more limited management depth and (iv) shorter operating histories.  Further, compared to large cap stocks, the securities of small and medium capitalization companies are more likely to experience sharper swings in market values, be harder to sell at times and at prices that the Fund’s investment adviser believes appropriate, and offer greater potential for gains and losses.
 
Foreign Securities:  The Fund may invest in foreign securities, including direct investments in securities of foreign issuers that are traded on a U.S. securities exchange or over the counter and investments in depository receipts (such as American Depositary Receipts (“ADRs”)), ETFs and other closed-end investment companies that represent indirect interests in securities of foreign issuers.  The Fund is not limited in the amount of assets it may invest in such foreign securities.  These investments involve certain risks not generally associated with investments in the securities of U.S. issuers, including the risk of fluctuations in foreign currency exchange rates, unreliable and untimely information about the issuers and political and economic instability.  These risks could result in the Fund’s investment adviser misjudging the value of certain securities or in a significant loss in the value of those securities.
 
The value of foreign securities is affected by changes in currency rates, foreign tax laws (including withholding and confiscatory taxes), government policies (in this country or abroad), relations between nations and trading, settlement, custodial and other operational risks.  In addition, the costs of investing abroad are generally higher than in the United States, and foreign securities markets may be less liquid, more volatile and less subject to governmental supervision than markets in the U.S.  As an alternative to holding foreign traded securities, the Fund may invest in dollar-denominated securities of foreign companies that trade
 

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Special Opportunities Fund, Inc.


Investment objectives and policies, principal risk factors

on U.S. exchanges or in the U.S. over-the-counter market (including depositary receipts as described below, which evidence ownership in underlying foreign securities, and ETFs as described above).
 
Because foreign companies are not subject to uniform accounting, auditing and financial reporting standards, practices and requirements comparable to those applicable to U.S. companies, there may be less publicly available information about a foreign company than about a domestic company.  Volume and liquidity in most foreign debt markets is less than in the United States and securities of some foreign companies are less liquid and more volatile than securities of comparable U.S. companies.  There is generally less government supervision and regulation of securities exchanges, broker dealers and listed companies than in the United States.  Mail service between the United States and foreign countries may be slower or less reliable than within the United States, thus increasing the risk of delayed settlements of portfolio transactions or loss of certificates for portfolio securities.  Payment for securities before delivery may be required.  In addition, with respect to certain foreign countries, including those with emerging markets, there is the possibility of expropriation or confiscatory taxation, political or social instability, or diplomatic developments which could affect investments in those countries.  For example, prior governmental approval for foreign investments may be required in some emerging market countries, and the extent of foreign investment may be subject to limitation in other emerging countries.  Moreover, individual foreign economies may differ favorably or unfavorably from the U.S. economy in such respects as growth of gross national product, rate of inflation, capital reinvestment, resource self-sufficiency and balance of payments position.  Foreign securities markets, while growing in volume and sophistication, are generally not as developed as those in the United States, and securities of some foreign issuers (particularly those located in developing countries) may be less liquid and more volatile than securities of comparable U.S. companies.
 
The Fund may purchase ADRs, international depositary receipts (“IDRs”) and global depository receipts (“GDRs”) which are certificates evidencing ownership of shares of foreign issuers and are alternatives to purchasing directly the underlying foreign securities in their national markets and currencies.  However, such depository receipts continue to be subject to many of the risks associated with investing directly in foreign securities.  These risks include foreign exchange risk as well as the political and economic risks associated with the underlying issuer’s country. ADRs, EDRs and GDRs may be sponsored or unsponsored.  Unsponsored receipts are established without the participation of the issuer.  Unsponsored receipts may involve higher expenses, they may not pass-through voting or other stockholder rights, and they may be less liquid.  Less information is normally available on unsponsored receipts.
 

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Special Opportunities Fund, Inc.


Investment objectives and policies, principal risk factors

Dividends paid on foreign securities may not qualify for the reduced federal income tax rates applicable to qualified dividends under the Code.  As a result, there can be no assurance as to what portion of the Fund’s distributions attributable to foreign securities will be designated as qualified dividend income.
 
Emerging Market Securities:  The Fund may invest up to 5% of its net assets in emerging market securities, although through its investments in ETFs, other investment companies or depository receipts that invest in emerging market securities, up to 20% of the Fund’s assets may be invested indirectly in issuers located in emerging markets.  The risks of foreign investments described above apply to an even greater extent to investments in emerging markets.  The securities markets of emerging countries are generally smaller, less developed, less liquid, and more volatile than the securities markets of the United States and developed foreign markets.  Disclosure and regulatory standards in many respects are less stringent than in the United States and developed foreign markets.  There also may be a lower level of monitoring and regulation of securities markets in emerging market countries and the activities of investors in such markets and enforcement of existing regulations has been extremely limited.  Many emerging countries have experienced substantial, and in some periods extremely high, rates of inflation for many years.  Inflation and rapid fluctuations in inflation rates have had and may continue to have very negative effects on the economies and securities markets of certain emerging countries.  Economies in emerging markets generally are heavily dependent upon international trade and, accordingly, have been and may continue to be affected adversely by trade barriers, exchange controls, managed adjustments in relative currency values, and other protectionist measures imposed or negotiated by the countries with which they trade.  The economies of these countries also have been and may continue to be adversely affected by economic conditions in the countries in which they trade.  The economies of countries with emerging markets may also be predominantly based on only a few industries or dependent on revenues from particular commodities.  In addition, custodial services and other costs relating to investment in foreign markets may be more expensive in emerging markets than in many developed foreign markets, which could reduce the Fund’s income from such securities.  In many cases, governments of emerging countries continue to exercise significant control over their economies, and government actions relative to the economy, as well as economic developments generally, may affect the Fund’s investments in those countries.  In addition, there is a heightened possibility of expropriation or confiscatory taxation, imposition of withholding taxes on interest payments, or other similar developments that could affect investments in those countries.  There can be no assurance that adverse political changes will not cause the Fund to suffer a loss of any or all of its investments.  Dividends paid by issuers in emerging market countries will generally not qualify for the reduced federal income tax rates applicable to qualified dividends under the Code.
 

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Special Opportunities Fund, Inc.


Investment objectives and policies, principal risk factors

Preferred Stocks:  The Fund may invest in preferred stocks.  Preferred stock, like common stock, represents an equity ownership in an issuer.  Generally, preferred stock has a priority of claim over common stock in dividend payments and upon liquidation of the issuer. Unlike common stock, preferred stock does not usually have voting rights.  Preferred stock in some instances is convertible into common stock.  Although they are equity securities, preferred stocks have characteristics of both debt and common stock.  Like debt, their promised income is contractually fixed.  Like common stock, they do not have rights to precipitate bankruptcy proceedings or collection activities in the event of missed payments.  Other equity characteristics are their subordinated position in an issuer’s capital structure and that their quality and value are heavily dependent on the profitability of the issuer rather than on any legal claims to specific assets or cash flows.
 
Investment in preferred stocks carries risks, including credit risk, deferral risk, redemption risk, limited voting rights, risk of subordination and lack of liquidity.  Fully taxable or hybrid preferred securities typically contain provisions that allow an issuer, at its discretion, to defer distributions for up to 20 consecutive quarters.  Distributions on preferred stock must be declared by the board of directors and may be subject to deferral, and thus they may not be automatically payable.  Income payments on preferred stocks may be cumulative, causing dividends and distributions to accrue even if not declared by the company’s board or otherwise made payable, or they may be non-cumulative, so that skipped dividends and distributions do not continue to accrue.  There is no assurance that dividends on preferred stocks in which the Fund invests will be declared or otherwise made payable.  The Fund may invest in non-cumulative preferred stock, although the Fund’s investment adviser would consider, among other factors, their non-cumulative nature in making any decision to purchase or sell such securities.
 
Shares of preferred stock have a liquidation value that generally equals the original purchase price at the date of issuance.  The market values of preferred stock may be affected by favorable and unfavorable changes impacting the issuers’ industries or sectors, including companies in the utilities and financial services sectors, which are prominent issuers of preferred stock.  They may also be affected by actual and anticipated changes or ambiguities in the tax status of the security and by actual and anticipated changes or ambiguities in tax laws, such as changes in corporate and individual income tax rates, and in the dividends received deduction for corporate taxpayers or the lower rates applicable to certain dividends.
 
Because the claim on an issuer’s earnings represented by preferred stock may become onerous when interest rates fall below the rate payable on the stock or for other reasons, the issuer may redeem preferred stock, generally after an initial period of call protection in which the stock is not redeemable.  Thus, in declining interest rate environments in particular, the Fund’s holdings of higher dividend
 

47

Special Opportunities Fund, Inc.


Investment objectives and policies, principal risk factors

paying preferred stocks may be reduced and the Fund may be unable to acquire securities paying comparable rates with the redemption proceeds.  In the event of a redemption, the Fund may not be able to reinvest the proceeds at comparable rates of return.
 
Convertible Securities.  The Fund may invest in convertible securities.  Convertible securities include fixed income securities that may be exchanged or converted into a predetermined number of shares of the issuer’s underlying common stock at the option of the holder during a specified period.  Convertible securities may take the form of convertible preferred stock, convertible bonds or debentures, units consisting of “usable” bonds and warrants or a combination of the features of several of these securities.  The investment characteristics of each convertible security vary widely, which allows convertible securities to be employed for a variety of investment strategies.  The Fund will exchange or convert convertible securities into shares of underlying common stock when, in the opinion of the Fund’s investment adviser, the investment characteristics of the underlying common shares will assist the Fund in achieving its investment objective.  The Fund may also elect to hold or trade convertible securities. In selecting convertible securities, the Fund’s investment adviser evaluates the investment characteristics of the convertible security as a fixed income instrument, and the investment potential of the underlying equity security for capital appreciation.  In evaluating these matters with respect to a particular convertible security, the Fund’s investment adviser considers numerous factors, including the economic and political outlook, the value of the security relative to other investment alternatives, trends in the determinants of the issuer’s profits, and the issuer’s management capability and practices.
 
The value of a convertible security, including, for example, a warrant, is a function of its “investment value” (determined by its yield in comparison with the yields of other securities of comparable maturity and quality that do not have a conversion privilege) and its “conversion value” (the security’s worth, at market value, if converted into the underlying common stock).  The investment value of a convertible security is influenced by changes in interest rates, with investment value declining as interest rates increase and increasing as interest rates decline.  The credit standing of the issuer and other factors may also have an effect on the convertible security’s investment value.  The conversion value of a convertible security is determined by the market price of the underlying common stock.  If the conversion value is low relative to the investment value, the price of the convertible security is governed principally by its investment value.  Generally, the conversion value decreases as the convertible security approaches maturity.  To the extent the market price of the underlying common stock approaches or exceeds the conversion price, the price of the convertible security will be increasingly influenced by its conversion value.  A convertible security generally will sell at a premium over its conversion value by the extent to which investors place value on
 

48

Special Opportunities Fund, Inc.


Investment objectives and policies, principal risk factors

the right to acquire the underlying common stock while holding a fixed income security.  A convertible security may be subject to redemption at the option of the issuer at a price established in the convertible security’s governing instrument.  If a convertible security held by the Fund is called for redemption, the Fund will be required to permit the issuer to redeem the security, convert it into the underlying common stock or sell it to a third party.  Any of these actions could have an adverse effect on the Fund’s ability to achieve its investment objective.
 
Real Estate Investment Trusts.  The Fund may invest in real estate investment trusts (“REITs”).  REITs are financial vehicles that pool investors’ capital to purchase or finance real estate.  Investments in REITs will subject the Fund to various risks. REIT share prices may decline because of adverse developments affecting the real estate industry and real property values.  In general, real estate values can be affected by a variety of factors, including supply and demand for properties, the economic health of the country or of different regions, and the strength of specific industries that rent properties. REITs often invest in highly leveraged properties.  Returns from REITs, which typically are small or medium capitalization stocks, may trail returns from the overall stock market.  In addition, changes in interest rates may hurt real estate values or make REIT shares less attractive than other income-producing investments. REITs are also subject to heavy cash flow dependency, defaults by borrowers and self-liquidation.
 
Qualification as a REIT under the Code in any particular year is a complex analysis that depends on a number of factors.  There can be no assurance that the entities in which the Fund invests with the expectation that they will be taxed as a REIT will qualify as a REIT.  An entity that fails to qualify as a REIT would be subject to a corporate level tax, would not be entitled to a deduction for dividends paid to its stockholders and would not pass through to its stockholders the character of income earned by the entity. If the Fund were to invest in an entity that failed to qualify as a REIT, such failure could significantly reduce the Fund’s yield on that investment.
 
REITs can be classified as equity REITs, mortgage REITs and hybrid REITs.  Equity REITs invest primarily in real property and earn rental income from leasing those properties. They may also realize gains or losses from the sale of properties.  Equity REITs will be affected by conditions in the real estate rental market and by changes in the value of the properties they own.  Mortgage REITs invest primarily in mortgages and similar real estate interests and receive interest payments from the owners of the mortgaged properties.  Mortgage REITs will be affected by changes in creditworthiness of borrowers and changes in interest rates.  Hybrid REITs invest both in real property and in mortgages.  Equity and mortgage REITs are dependent upon management skills, may not be diversified and are subject to the risks of financing projects.
 

49

Special Opportunities Fund, Inc.


Investment objectives and policies, principal risk factors

Dividends paid by REITs will not generally qualify for the reduced U.S. federal income tax rates applicable to qualified dividends under the Code.
 
The Fund’s investments in REITs may include an additional risk to stockholders.  Some or all of a REIT’s annual distributions to its investors may constitute a non-taxable return of capital.  Any such return of capital will generally reduce the Fund’s basis in the REIT investment, but not below zero.  To the extent the distributions from a particular REIT exceed the Fund’s basis in such REIT, the Fund will generally recognize gain.  In part because REIT distributions often include a nontaxable return of capital, trust distributions to stockholders may also include a nontaxable return of capital.  Stockholders that receive such a distribution will also reduce their tax basis in their common shares of the Fund, but not below zero.  To the extent the distribution exceeds a stockholder’s basis in the Fund’s common shares such stockholder will generally recognize a capital gain.
 
The Fund does not have any investment restrictions with respect to investments in REITs other than its concentration policy which limits its investments in REITs to no more than 25% of its assets.
 
Issuer Risk:  The value of an issuer’s securities that are held in the Fund’s portfolio may decline for a number of reasons which directly relate to the issuer, such as management performance, financial leverage and reduced demand for the issuer’s goods and services.
 
Foreign Currency Risk:  Although the Fund will report its NAV and pay expenses and distributions in U.S. dollars, the Fund may invest in foreign securities denominated or quoted in currencies other than the U.S. dollar.  Therefore, changes in foreign currency exchange rates will affect the U.S. dollar value of the Fund’s investment securities and NAV.  For example, even if the securities prices are unchanged on their primary foreign stock exchange, the Fund’s NAV may change because of a change in the rate of exchange between the U.S. dollar and the trading currency of that primary foreign stock exchange.  Certain currencies are more volatile than those of other countries and Fund investments related to those countries may be more affected.  Generally, if a foreign currency depreciates against the dollar (i.e., if the dollar strengthens), the value of the existing investment in the securities denominated in that currency will decline.  When a given currency appreciates against the dollar (i.e., if the dollar weakens), the value of the existing investment in the securities denominated in that currency will rise.  Certain foreign countries may impose restrictions on the ability of foreign securities issuers to make payments of principal and interest to investors located outside of the country, due to a blockage of foreign currency exchanges or otherwise.
 
Defensive Positions:  During periods of adverse market or economic conditions, the Fund may temporarily invest all or a substantial portion of its net assets in cash or cash equivalents.  The Fund would not be pursuing its investment objective in these circumstances and could miss favorable market developments.
 

50

Special Opportunities Fund, Inc.


Investment objectives and policies, principal risk factors

Risk Characteristics of Options and Futures:  Options and futures transactions can be highly volatile investments. Successful hedging strategies require the anticipation of future movements in securities prices, interest rates and other economic factors. When a fund uses futures contracts and options as hedging devices, the prices of the securities subject to the futures contracts and options may not correlate with the prices of the securities in a portfolio. This may cause the futures and options to react to market changes differently than the portfolio securities. Even if expectations about the market and economic factors are correct, a hedge could be unsuccessful if changes in the value of the portfolio securities do not correspond to changes in the value of the futures contracts. The ability to establish and close out futures contracts and options on futures contracts positions depends on the availability of a secondary market. If these positions cannot be closed out due to disruptions in the market or lack of liquidity, losses may be sustained on the futures contract or option. In addition, the Fund’s use of options and futures may have the effect of reducing gains made by virtue of increases in value of the Fund’s common stock holdings.
 
Securities Lending Risk:  Securities lending is subject to the risk that loaned securities may not be available to the Fund on a timely basis and the Fund may, therefore, lose the opportunity to sell the securities at a desirable price.  Any loss in the market price of securities loaned by the Fund that occurs during the term of the loan would be borne by the Fund and would adversely affect the Fund’s performance.  Also, there may be delays in recovery, or no recovery, of securities loaned or even a loss of rights in the collateral should the borrower of the securities fail financially while the loan is outstanding. The Fund would not have the right to vote any securities having voting rights during the existence of the loan.
 
Discount Risk:  Historically, the shares of the Fund, as well as those of other closed-end investment companies, have frequently traded at a discount to their NAV. Any premium or discount to NAV often fluctuates over time. See “Price Range of Common Stock.”
 
Other Risks:  In addition to the risks detailed above, the Fund also has investments in auction rate preferred securities, business development companies, special purpose acquisition vehicles, liquidation claims, warrants and rights.  All of these other investments can subject the Fund to various risks. Any of these investments could have an adverse effect on the Fund’s ability to achieve its investment objective.
 
Investment transactions and investment income—Investment transactions are recorded on the trade date.  Realized gains and losses from investment transactions are calculated using the identified cost method.  Dividend income is recorded on the ex-dividend date.  Interest income is recorded on an accrual basis.
 

51

Special Opportunities Fund, Inc.


Investment objectives and policies, principal risk factors

Discounts are accreted and premiums are amortized using the effective yield method as adjustments to interest income and the identified cost of investments.
 
Dividends and distributions—On March 4, 2019, the Fund received authorization from the U.S. Securities and Exchange Commission (the “SEC”) that permits the Fund to distribute long-term capital gains to stockholders more than once per year. Accordingly, the Board approved the implementation of a Managed Distribution Plan (“MDP”) to make monthly cash distributions to stockholders. Under the MDP, distributions will be made from current income, supplemented by realized capital gains and, to the extent necessary, paid in capital. In the year ended December 31, 2023, the Fund made monthly distributions to common stockholders at an annual rate of 8%, based on the NAV of the Fund’s common shares as of the close of business on the last business day of the previous year.  Dividends and distributions to common shareholders are recorded on the ex-dividend date.  The amount of dividends from net investment income and distributions from net realized capital gains was determined in accordance with federal income tax regulations, which may differ from U.S. generally accepted accounting principles.  These “book/tax” differences are either considered temporary or permanent in nature.  To the extent these differences are permanent in nature, such amounts are reclassified within the capital accounts based on their federal tax-basis treatment; temporary differences do not require reclassification.
 
The Fund has made certain investments in Real Estate Investment Trusts (“REITs”) which pay distributions to their shareholders based upon available funds from operations. Each REIT reports annually the tax character of its distributions. It is quite common for these distributions to exceed the REIT’s taxable earnings and profits resulting in the excess portion of such distributions being designated as a return of capital or long-term capital gain. The Fund intends to include the gross distributions from such REITs in its distributions to its shareholders; accordingly, a portion of the distributions paid to the Fund and subsequently distributed to shareholders may be re-characterized. The final determination of the amount of the Fund’s return of capital distribution for the period will be made after the end of each calendar year.
 
Holders of Convertible Preferred Stock receive calendar quarterly dividends at the rate of 2.75% of the Subscription Price per year. Dividends on the Convertible Preferred Stock are fully cumulative, and accumulate without interest from the date of original issuance of the Convertible Preferred Stock.
 

52

Special Opportunities Fund, Inc.


General information (unaudited)

The Fund
Special Opportunities Fund, Inc. (the “Fund”) is a diversified, closed-end management investment company whose common shares trade on the New York Stock Exchange (“NYSE”). The Fund’s NYSE trading symbol is “SPE.” On April 21, 2010 the Fund’s symbol changed from “PIF” to “SPE.” Comparative net asset value and market price information about the Fund is available weekly in various publications.
 
Annual meeting of shareholders held on December 7, 2023
The Fund held an annual meeting of shareholders on December 7, 2023. As of the record date, October 6, 2023, there were 11,182,133 shares of the Fund’s common stock issued and outstanding and 2,287,118 shares of the Fund’s preferred stock issued and outstanding. The results of the voting for the proposals were as follows:
 
Proposal 1(a) To elect four Directors to the Fund’s Board of Directors, to be elected by the holders of the Fund’s common stock and preferred stock, voting together as a single class, to serve until the Fund’s Annual Meeting of Stockholders in 2024 and until their successors have been duly elected and qualified.
 
Proposal to elect Andrew Dakos as a director:
       
FOR
% of Quorum
% of O/S
WITHHELD
7,260,165
66.86%
53.90%
3,598,725
       
Proposal to elect Ben Harris as a director:
       
FOR
% of Quorum
% of O/S
WITHHELD
7,224,308
66.53%
53.64%
3,634,582
       
Proposal to elect Gerald Hellerman as a director:
       
FOR
% of Quorum
% of O/S
WITHHELD
7,180,858
66.13%
53.31%
3,678,132
       
Proposal to elect Charles C. Walden as a director:
       
FOR
% of Quorum
% of O/S
WITHHELD
7,199,711
66.30%
53.45%
3,659,179


53

Special Opportunities Fund, Inc.


General information (unaudited)

Proposal 1(b) To elect two Directors to the Fund’s Board of Directors, to be elected by the holders of the Fund’s preferred stock, voting as a separate class, to serve until the Fund’s Annual Meeting of Stockholders in 2024 and until their successors have been duly elected and qualified.
 
Proposal to elect Phillip Goldstein as a director:
 
FOR
% of Quorum
% of O/S
WITHHELD
2,113,869
98.05%
92.43%
42,126
       
Proposal to elect Marc Lunder as a director:
 
FOR
% of Quorum
% of O/S
WITHHELD
2,113,869
98.05%
92.43%
42,126

O/S – outstanding shares
 

54

Special Opportunities Fund, Inc.


General information (unaudited)

Tax information
The Fund designated 14.55% of its ordinary income distribution for the year ended December 31, 2023, as qualified dividend income under the Jobs and Growth Tax Relief Reconciliation Act of 2003.
 
For the year ended December 31, 2023, 6.24% of dividends paid from net ordinary income qualified for the dividends received deduction available to corporate shareholders.
 
The Fund designated 0.00% of taxable ordinary income distributions designated as short-term capital gain distributions under Internal Revenue Section 871 (k)(2)(C).
 
Quarterly Form N-PORT portfolio schedule
The Fund files its complete schedule of portfolio holdings with the SEC for the first and third quarters of each fiscal year on Form N-PORT.  The Fund’s Forms N-PORT are available on the SEC’s Web site at http://www.sec.gov.  Additionally, you may obtain copies of Forms N-PORT from the Fund upon request by calling 1-877-607-0414.
 
Proxy voting policies, procedures and record
You may obtain a description of the Fund’s (1) proxy voting policies, (2) proxy voting procedures and (3) information regarding how the Fund voted any proxies related to portfolio securities during the most recent 12-month period ended June 30 for which an SEC filing has been made, without charge, upon request by contacting the Fund directly at 1-877-607-0414, or on the EDGAR Database on the SEC’s Web site (http://www.sec.gov).
 

55

Special Opportunities Fund, Inc.


Supplemental information (unaudited)

The following table sets forth the directors and officers of the Fund, his name, address, age, position with the Fund, term of office and length of service with the Fund, principal occupation or employment during the past five years and other directorships held at December 31, 2023.
 
Additional information about the Directors and Officers of the Fund is included in the Fund’s most recent Form N-2.
 
   
Term of
 
Number of
Other
   
Office
 
Portfolios
Directorships
   
and
 
in Fund
held by
 
Position(s)
Length
Principal Occupation
Complex
Director During
Name, Address
Held with
of Time
During the Past
Overseen
the Past
and Age*
the Fund
Served
Five Years
by Director**
Five Years
INTERESTED DIRECTORS
           
Andrew Dakos***
President
1 year;
Partner of the Adviser since
1
Director, Brookfield
(57)
as of
Since
2009; Partner of Ryan
 
DTLA Fund Office
 
October
2009
Heritage, LLP since 2019;
 
Trust Investor, Inc.;
 
2009.
 
Principal of the former
 
Trustee, Crossroads
     
general partner of several
 
Liquidating Trust
     
private investment partnerships
 
(until 2020);
     
in the Bulldog Investors group
 
Trustee, High
     
of private funds.
 
Income Securities
         
Fund; Chairman,
         
Swiss Helvetia
         
Fund, Inc.
           
Phillip Goldstein***
Chairman
1 year;
Partner of the Adviser since
1
Chairman, Mexico
(79)
and
Since
2009; Partner of Ryan
 
Equity and Income
 
Secretary
2009
Heritage, LLP since 2019;
 
Fund, Inc.; Director,
 
as of
 
Principal of the former
 
MVC Capital, Inc.
 
October
 
general partner of several
 
(until 2020);
 
2009.
 
private investment partnerships
 
Director, Brookfield
     
in the Bulldog Investors group
 
DTLA Fund Office
     
of private funds.
 
Trust Investor, Inc.;
         
Trustee, Crossroads
         
Liquidating Trust
         
(until 2020);
         
Chairman, High
         
Income Securities
         
Fund; Director,
         
Swiss Helvetia
         
Fund, Inc.


56

Special Opportunities Fund, Inc.


Supplemental information (unaudited)

   
Term of
 
Number of
Other
   
Office
 
Portfolios
Directorships
   
and
 
in Fund
held by
 
Position(s)
Length
Principal Occupation
Complex
Director During
Name, Address
Held with
of Time
During the Past
Overseen
the Past
and Age*
the Fund
Served
Five Years
by Director**
Five Years
INDEPENDENT DIRECTORS
           
Gerald Hellerman
1 year;
Managing Director of Hellerman
1
Director, Mexico
(86)
 
Since
Associates (a financial and
 
Equity and Income
   
2009
corporate consulting firm) since
 
Fund, Inc.; Trustee,
     
1993 (which terminated activities
 
Fiera Capital Series
     
as of December, 31, 2013).
 
Trust (until 2023);
         
Trustee, High
         
Income Securities
         
Fund; Director,
         
Swiss Helvetia
         
Fund, Inc.; Director,
         
MVC Capital, Inc.
         
(until 2020);
         
Trustee, Crossroads
         
Liquidating Trust
         
(until 2020).
           
Marc Lunder
1 year;
Managing Member of Lunder
1
None
(60)
 
Effective
Capital LLC.
   
   
January 1,
     
   
2015
     
           
Ben Harris
1 year;
Executive Chairman of
1
Trustee,
(55)
 
Since
Hormel Harris Investments, LLC;
 
High Income
   
2009
Principal of NBC Bancshares, LLC;
 
Securities Fund.
     
Chief Executive Officer of Crossroads
   
     
Capital, Inc.; Administrator of
   
     
Crossroads Liquidating Trust.
   
           
Charles C. Walden
1 year;
President and Owner of Sound
1
Independent
(79)
 
Since
Capital Associates, LLC
 
Chairman, Third
   
2009
(consulting firm).
 
Avenue Funds
         
(fund complex
         
consisting of three
         
funds and one
         
variable series trust)
         
(until 2019).


57

Special Opportunities Fund, Inc.


Supplemental information (unaudited)

   
Term of
 
Number of
Other
   
Office
 
Portfolios
Directorships
   
and
 
in Fund
held by
 
Position(s)
Length
Principal Occupation
Complex
Director During
Name, Address
Held with
of Time
During the Past
Overseen
the Past
and Age*
the Fund
Served
Five Years
by Director**
Five Years
OFFICERS
           
Andrew Dakos***
President
1 year;
Partner of the Adviser since
n/a
n/a
(57)
as of
Since
2009; Partner of Ryan
   
 
October
2009
Heritage, LLP since 2019;
   
 
2009.
 
Principal of the former
   
     
general partner of several
   
     
private investment partnerships
   
     
in the Bulldog Investors group
   
     
of private funds.
   
           
Rajeev Das***
Vice-
1 year;
Principal of the Adviser and
n/a
n/a
(55)
President
Since
Ryan Heritage, LLP.
   
 
as of
2009
     
 
October
       
 
2009.
       
           
Phillip Goldstein***
Chairman
1 year;
Partner of the Adviser
n/a
n/a
(79)
and
Since
since 2009; Partner of Ryan
   
 
Secretary
2009
Heritage, LLP since 2019;
   
 
as of
 
Principal of the
   
 
October
 
former general partner of
   
 
2009.
 
several private investment
   
     
partnerships in the Bulldog
   
     
Investors group of funds.
   
           
Stephanie Darling***
Chief
1 year;
General Counsel and Chief
n/a
n/a
(53)
Compliance
Since
Compliance Officer of
   
 
Officer
2020
Bulldog Investors, LLP;
   
 
as of
 
Chief Compliance Officer –
   
 
April
 
Ryan Heritage, LLP, High
   
 
2020.
 
Income Securities Fund,
   
     
Swiss Helvetia Fund, and
   
     
Mexico Equity and Income
   
     
Fund; Principal, the Law
   
     
Office of Stephanie Darling;
   
     
Editor-In-Chief, The
   
     
Investment Lawyer.
   


58

Special Opportunities Fund, Inc.


Supplemental information (unaudited)

   
Term of
 
Number of
Other
   
Office
 
Portfolios
Directorships
   
and
 
in Fund
held by
 
Position(s)
Length
Principal Occupation
Complex
Director During
Name, Address
Held with
of Time
During the Past
Overseen
the Past
and Age*
the Fund
Served
Five Years
by Director**
Five Years
Thomas Antonucci***
Chief
1 year;
Director of Operations
n/a
n/a
(55)
Financial
Since
of the Adviser and Ryan
   
 
Officer
2014
Heritage, LLP.
   
 
and
       
 
Treasurer
       
 
as of
       
 
January
       
 
2014.
       

*
 
The address for all directors and officers is c/o Special Opportunities Fund, Inc., 615 East Michigan Street, Milwaukee, WI 53202.
**
 
The Fund Complex is comprised of only the Fund.
***
 
Messrs. Dakos, Goldstein, Das, Antonucci and Ms. Darling are each considered an “interested person” of the Fund within the meaning of the 1940 Act because of their affiliation with Bulldog Investors, LLP, the Adviser, and their positions as officers of the Fund.


59

Special Opportunities Fund, Inc.


Board approval of investment advisory agreement (unaudited)

At its in-person meeting held on September 14, 2023, the Board of Directors (the “Board”) of Special Opportunities Fund, Inc. (the “Fund”) met to consider the renewal of the Investment Advisory Agreement (the “Advisory Agreement”) between the Fund and Bulldog Investors, LLP (the “Adviser”). The Independent Directors (as defined below) held a telephonic executive session on September 6, 2023 (the “September 6, 2023 Meeting”) to review materials related to the renewal of the Advisory Agreement. The Board received and discussed a memorandum from the Fund’s independent legal counsel regarding the duties and responsibilities of the Board and the Independent Directors under the Investment Company Act of 1940, as amended (the “1940 Act”), in reviewing advisory contracts. Based on their evaluation of the information provided, the Directors, by a unanimous vote (including a separate vote of the Directors who are not “interested persons,” as that term is defined in the 1940 Act, as amended (the “Independent Directors”)), approved the continuation of the Advisory Agreement for an additional one-year term.
 
In considering the renewal of the Advisory Agreement and reaching their conclusions, the Independent Directors reviewed and analyzed various factors that they determined were relevant, including (a) the nature, extent, and quality of the services to be provided by the Adviser; (b) the investment performance of the Fund assets managed by the Adviser; (c) the cost of the services to be provided and the profits to be realized by the Adviser from its relationship with the Fund; (d) the extent to which economies of scale (if any) would be realized as the Fund grows; and (e) fee comparisons of the advisory services and fees similar to those of the Investment Adviser. The Independent Directors evaluated each of these factors based on their own direct experience with the Adviser and in consultation with their independent counsel. No one factor was determinative in the Board’s decision to approve the continuance of the Advisory Agreement. Greater detail regarding the Independent Directors’ consideration of the factors that led to their decision to approve the continuance of the Advisory Agreement is set forth below.
 
The materials which had been prepared by the Adviser in response to a questionnaire (known as a “15(c) questionnaire”) provided to the Adviser by Fund counsel with respect to certain matters that counsel believed relevant to the annual continuation of the Advisory Agreement under Section 15 of the 1940 Act, distributed to the Directors and reviewed by the Independent Directors together with counsel at the September 6, 2023 Meeting included, among other things, information regarding: (a) the Adviser’s financial soundness; (b) information on the cost to the Adviser of advising the Fund and the Adviser’s profitability in connection with such advisory services; (c) the experience and responsibilities of key personnel at the Adviser; (d) the risk management policies and procedures adopted by the Adviser; (e) the investment performance of the Fund as compared to peer and/or
 

60

Special Opportunities Fund, Inc.


Board approval of investment advisory agreement (unaudited)

comparable funds; (f) the Adviser’s policy with respect to selection of broker-dealers and allocation of portfolio transactions; (g) fees of the Fund as compared to peer and/or comparable funds; (h) the profitability to the Adviser derived from its relationship to the Fund; (i) the Adviser’s compliance program and chief compliance officer; (j) the Adviser’s policy with respect to proxy voting; (k) affiliates and possible conflicts; and (l) other material factors affecting the Adviser.
 
The Directors reviewed the Adviser’s financial information and discussed the profitability of the Adviser as it relates to advising the Fund. The Independent Directors considered both the direct and indirect benefits to the Adviser from advising the Fund. These considerations were based on material requested by the Directors specifically for the meeting, as well as the in-person presentations made by the Adviser over the course of the year. After further discussion, the Independent Directors concluded that the Adviser’s profit from advising the Fund currently was not excessive and that the Adviser had adequate financial strength to support the services to the Fund.
 
The Independent Directors then assessed the overall quality of services provided to the Fund. The Independent Directors considered the Adviser’s specific responsibilities in all aspects of day-to-day management of the Fund, as well as the qualifications, experience and responsibilities of the portfolio managers and other key personnel at the Adviser involved in the day-to-day activities of the Fund. The Independent Directors noted the unique investment strategy of the Fund and the knowledge and expertise required by the Adviser’s personnel. The Independent Directors also considered the operational strength of the Adviser. The Independent Directors considered the favorable history, reputation, qualification and background of the Adviser, as well as the qualifications of its personnel and financial condition. The Independent Directors then reviewed the Bulldog Investors, LLP organizational chart as well as the affiliated entity organizational chart. The Independent Directors concluded that the Adviser had sufficient quality and depth of personnel, resources, investment methods and compliance policies and procedures to perform its duties under the Investment Advisory Agreement and that the nature, overall quality, and extent of the management services were satisfactory and reliable.
 
The Independent Directors reviewed the personnel responsible for providing services to the Fund and concluded, based on their experience and interaction with the Adviser, that the Adviser (a) was able to retain quality personnel, (b) exhibited a high level of diligence and attention to detail in carrying out its responsibilities under the Investment Advisory Agreement, (c) was very responsive to the requests of the Independent Directors and the Fund’s CCO, (d) had
 

61

Special Opportunities Fund, Inc.


Board approval of investment advisory agreement (unaudited)

consistently kept the Board apprised of developments related to the Fund and the industry in general and (e) continued to demonstrate the ability to grow the Fund over time via investment returns.
 
The Independent Directors discussed the performance of the Fund for the year-to-date, one-year, three-year, five-year, and ten-year periods ended June 30, 2023. In assessing the quality of the portfolio management services delivered by the Adviser, the Independent Directors also compared the short-term and long-term performance of the Fund on both an absolute basis and in comparison to a peer fund group with data provided by Morningstar, Inc. (the “Peer Group”) and assembled by Fund Services independently from the Adviser. The Independent Directors noted that the Fund’s NAV performance was above the peer group average for the one-year, three-year and five-year periods, but below the peer group average for the ten-year period. It was also noted by the Independent Directors that the Adviser had provided select data on the Fund’s peers that the Adviser believed were most comparable to the investment style of the Fund. The Independent directors also noted that they review the investment performance of the Fund at each quarterly meeting. After considering all of the information, the Independent Directors concluded that the Adviser has obtained reasonable returns for the Fund while minimizing risk. Although past performance is not a guarantee or indication of future results, the Independent Directors determined that the Fund and its shareholders were likely to benefit from the Adviser’s continued management.
 
The Independent Directors then turned to a more focused review of the cost of services and the structure of the Adviser’s fees. The Independent Directors reviewed information prepared by the Adviser, as well as by Fund Services comparing the Fund’s contractual advisory fee with a peer group of funds and comparing the Fund’s overall expense ratio to the expense ratios of the Peer Group. The Independent Directors noted that the contractual investment advisory fee for the Fund of 1.00% was below the 1.02% Peer Group average. The Independent Directors further noted that the then current expense ratio of 1.99% for the Fund, which included the advisory fee on the preferred assets, was greater than the Peer Group average expense ratio of 1.50%. It was noted that the Fund is unique in its industry due to its activist investment strategy and true comparisons are difficult. Discussion ensued regarding the selection of the comparable funds by the Adviser and their use of leverage. Following a thorough discussion, the Independent Directors concluded that the Fund’s expenses and the management fee paid to the Adviser were fair and not unreasonable in light of the experience and commitment of the Adviser, as well as the comparative performance, expense and management fee information provided.
 

62

Special Opportunities Fund, Inc.


Board approval of investment advisory agreement (unaudited)

After due consideration of the written and oral presentations, the Independent Directors concluded that the nature and scope of the advisory services provided was reasonable and appropriate in relation to the advisory fee and in relation to peer comparisons, that the level of services to be provided by the Adviser were expected to be maintained and that the quality of service was expected to remain high.
 
Based on the factors discussed above, the Board approved the continuance of the Advisory Agreement between the Fund and Adviser on September 14, 2023.
 

63

Special Opportunities Fund, Inc.


New York Stock Exchange certifications (unaudited)

On December 21, 2023, the Fund submitted an annual certification to the New York Stock Exchange (“NYSE”) in which the Fund’s president certified that he was not aware, as of the date of the certification, of any violation by the Fund of the NYSE’s Corporate Governance listing standards.
 

64

Special Opportunities Fund, Inc.


Privacy policy notice

The following is a description of the Fund’s policies regarding disclosure of nonpublic personal information that you provide to the Fund or that the Fund collects from other sources.  In the event that you hold shares of the Fund through a broker-dealer or other financial intermediary, the privacy policy of the financial intermediary would govern how your nonpublic personal information would be shared with unaffiliated third parties.
 
CATEGORIES OF INFORMATION THE FUND COLLECTS.  The Fund collects the following nonpublic personal information about you:
 
 
1.
Information from the Consumer: this category includes information the Fund receives from you on or in applications or other forms, correspondence, or conversations (such as your name, address, phone number, social security number, assets, income and date of birth); and
     
 
2.
Information about the Consumer’s transactions: this category includes information about your transactions with the Fund, its affiliates, or others (such as your account number and balance, payment history, parties to transactions, cost basis information, and other financial information).

CATEGORIES OF INFORMATION THE FUND DISCLOSES.  The Fund does not disclose any nonpublic personal information about their current or former shareholders to unaffiliated third parties, except as required or permitted by law.  The Fund is permitted by law to disclose all of the information it collects, as described above, to its service providers (such as the Custodian, administrator and transfer agent) to process your transactions and otherwise provide services to you.
 
CONFIDENTIALITY AND SECURITY.  The Fund restricts access to your nonpublic personal information to those persons who require such information to provide products or services to you.  The Fund maintains physical, electronic and procedural safeguards that comply with federal standards to guard your nonpublic personal information.
 
This privacy policy notice is not a part of the shareholder report.
 

65

Investment Adviser
Bulldog Investors, LLP
Park 80 West
250 Pehle Avenue, Suite 708
Saddle Brook, NJ  07663

Administrator and Fund Accountant
U.S. Bank Global Fund Services
615 East Michigan Street
Milwaukee, WI  53202

Custodian
U.S. Bank, N.A.
Custody Operations
1555 North RiverCenter Drive, Suite 302
Milwaukee, WI  53212

Transfer Agent and Registrar
Equiniti Trust Company, LLC
48 Wall Street, Floor 23
New York, NY  10005

Fund Counsel
Blank Rome LLP
1271 Avenue of the Americas
New York, NY  10020

Independent Registered Public Accounting Firm
Tait, Weller & Baker LLP
Two Liberty Place
50 South 16th Street, Suite 2900
Philadelphia, PA  19102

Board of Directors
Andrew Dakos
Phillip Goldstein
Ben Harris
Gerald Hellerman
Marc Lunder
Charles Walden





Special Opportunities Fund, Inc.
1-877-607-0414
www.specialopportunitiesfundinc.com



(b) Not applicable for this Registrant.

Item 2. Code of Ethics.

The registrant has adopted a code of ethics that applies to the registrant’s principal executive officer and principal financial officer.  The Registrant has not made any amendments to its Code of Ethics during the period covered by this report.  The registrant has not granted any waivers from any provisions of the code of ethics during the period covered by this report.

Item 3. Audit Committee Financial Expert.

The registrant’s board of directors has determined that there is at least one audit committee financial expert serving on its audit committee.  Marc Lunder is the “audit committee financial expert” and is considered to be “independent” as each term is defined in Item 3 of Form N‑CSR.

Item 4. Principal Accountant Fees and Services.

(a) Audit Fees:

For the fiscal years ended December 31, 2023 and December 31, 2022, the aggregate Tait, Weller & Baker LLP (“TWB”) audit fees for professional services rendered to the registrant were approximately $39,000 and $39,000, respectively.

Fees included in the audit fees category are those associated with performing an audit of the registrant’s annual financial statements or services that are normally provided by the accountant in connection with statutory and regulatory filings or engagements.

(b) Audit-Related Fees:

For the fiscal years ended December 31, 2023 and December 31, 2022, the aggregate audit-related fees billed by TWB for services rendered to the registrant that are related to the performance of the audit, but not reported as audit fees, were approximately $2,000 and $2,000, respectively.

Fees included in the audit-related category are those associated with (1) the review of the semi-annual report.

The Audit Committee pre-approved the fees for TWB for the cursory review of the semi-annual report.  There were no other audit-related fees required to be approved pursuant to paragraph (c)(7)(ii) of Rule 2-01 of Regulation S-X during the fiscal periods indicated above.

(c) Tax Fees:

For the fiscal years ended December 31, 2023 and December 31, 2022, the aggregate tax fees billed by TWB for professional services rendered to the registrant were $4,000 and $4,000, respectively.

Fees included in the tax fees category comprise all services performed by professional staff in the independent accountant’s tax division except those services related to the audits. This category comprises fees for review of tax compliance, Federal income tax returns and excise tax calculations.

There were no tax fees required to be approved pursuant to paragraph (c)(7)(ii) of Rule 2-01 of Regulation S-X during the fiscal periods indicated above.

(d) All Other Fees:

In the fiscal years ended December 31, 2023 and December 31, 2022, there were no fees billed by TWB for products and services, other than the services reported in Item 4(a)-(c) above, rendered to the registrant.

There were no “all other fees” required to be approved pursuant to paragraph (c)(7)(ii) of Rule 2-01 of Regulation S-X during the fiscal periods indicated above.

(e)(1) Audit Committee Pre-Approval Policies and Procedures:

The audit committee has adopted pre-approval policies and procedures that require the audit committee to pre-approve all audit and non-audit services of the registrant, including services provided to any entity affiliated with the registrant.

(e)(2) Services approved pursuant to paragraph (c)(7)(i)(C) of Rule 2-01 of Regulation S-X:

Audit-Related Fees:

There were no amounts that were approved by the audit committee pursuant to the de minimis exception for the fiscal years ended December 31, 2023 and December 31, 2022 on behalf of the registrant.

There were no amounts that were required to be approved by the audit committee pursuant to the de minimis exception for the fiscal years ended December 31, 2023 and December 31, 2022 on behalf of the registrant’s service providers that relate directly to the operations and financial reporting of the registrant.

Tax Fees:

There were no amounts that were approved by the audit committee pursuant to the de minimis exception for the fiscal years ended December 31, 2023 and December 31, 2022 on behalf of the registrant.

There were no amounts that were required to be approved by the audit committee pursuant to the de minimis exception for the fiscal years ended December 31, 2023 and December 31, 2022 on behalf of the registrant’s service providers that relate directly to the operations and financial reporting of the registrant.

All Other Fees:

There were no amounts that were approved by the audit committee pursuant to the de minimis exception for the fiscal years ended December 31, 2023 and December 31, 2022 on behalf of the registrant.

There were no amounts that were required to be approved by the audit committee pursuant to the de minimis exception for the fiscal years ended December 31, 2023 and December 31, 2022 on behalf of the registrant’s service providers that relate directly to the operations and financial reporting of the registrant.

(f) All of the principal accountant’s hours spent on auditing the registrant’s financial statements were attributed to work performed by full‑time permanent employees of the principal accountant.

(g) For the fiscal years ended December 31, 2023 and December 31, 2022, the aggregate fees billed by TWB for non-audit services rendered on behalf of the registrant, its investment adviser and any entity controlling, controlled by, or under common control with the adviser that provides (or provided during the relevant fiscal period) services to the registrant for each of the last two fiscal periods of the registrant is shown in the table below.

   
December 31, 2023
December 31, 2022
Registrant
 
$6,000
$6,000
Registrant’s Investment Adviser
 
$0
$0

(h) The registrant’s audit committee was not required to consider whether the provision of non-audit services that were rendered to the registrant’s investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the investment adviser that provides ongoing services to the registrant that were not pre-approved pursuant to paragraph (c)(7)(ii) of Rule 2-01 of Regulation S-X is compatible with maintaining the principal accountant’s independence.

(i) Not applicable

(j) Not applicable

Item 5. Audit Committee of Listed Registrants.

The Audit Committee is comprised of Mr. Marc Lunder, Mr. Ben H. Harris, Mr. Charles C. Walden and Mr. Gerald Hellerman.

Item 6. Investments.

(a)
Schedule of Investments is included as part of the report to shareholders filed under Item 1 of this Form.
 
(b)   Not Applicable.

Item 7. Disclosure of Proxy Voting Policies and Procedures for Closed-End Management Investment Companies.

The registrant's policy regarding proxy voting is to delegate the voting of proxies with respect to securities owned by the Fund to the Adviser.  The Adviser's policies and procedures regarding proxy voting are below.
 
Bulldog Investors, LLP
 
Proxy Voting Policies and Procedures

Proxy Voting Policies

Bulldog Investors believes that the right to vote on issues submitted to shareholder vote, such as election of directors and important matters affecting a company’s structure and operations, can impact the value of its investments.  Bulldog Investors generally analyzes the proxy statements of issuers of stock owned by Bulldog Investors’ clients, as necessary and, other than in connection with routine meetings of open-end investment companies, votes proxies on behalf of such clients.

Bulldog Investors’ decisions with respect to proxy issues are made in light of the anticipated impact of the issue on the value of the investment.  Proxies are voted solely in the interests of Bulldog Investors’ clients.  Inherent in Bulldog Investors’ authority to vote proxies on behalf of its clients is the authority to refrain from voting and/or refrain from attending a shareholder meeting, if Bulldog Investors determines that refraining from such action is in the best interest of its clients.

Proxy Voting Procedures

In evaluating proxy statements, Bulldog Investors relies upon its own fundamental research, and information presented by company management and others.  Bulldog Investors does not delegate its proxy voting responsibility to a third party proxy voting service.

Proxy Voting Guidelines

Bulldog Investors will generally vote proxies in favor of proposals that, in the opinion of the portfolio managers, seek to enhance shareholder value and shareholder democracy. Bulldog Investors will generally vote proxies against any director who has voted to take action to materially impair shareholder voting rights (e.g., has voted to “opt in” to any state’s control share statute).

Special Opportunities Fund, Inc. (“SPE”).  With respect to proxies of closed-end investment companies held by SPE, in order to comply with Section 12(d) of the Investment Company Act of 1940, Bulldog Investors will “mirror vote” all such proxies received by SPE, unless Bulldog Investors deems it appropriate to seek instructions from SPE shareholders with regard to such vote. In such circumstances, Bulldog Investors will vote such proxies proportionally based upon the total number of shares owned by those shareholders that provide instructions. Bulldog Investors will post such instructions on SPE’s website and will send an email indicating that it is seeking instructions to those SPE shareholders who have requested to receive such information.  In each semi-annual report to SPE shareholders, they are solicited to request to receive such information.

All Clients.  In certain circumstances, Bulldog Investors may enter into a settlement agreement with an issuer of stock owned by Bulldog Investors’ clients that requires Bulldog Investors to vote shares of such stock (or the stock of an affiliate of the issuer) held by clients in a manner that deviates from these Policies and Procedures.  In entering into any such agreement, Bulldog Investors has determined that the anticipated impact of entering into such settlement agreement is in the interests of Bulldog Investors’ clients.

Monitoring and Resolving Conflicts of Interest

When reviewing proxy statements and related research materials, Bulldog Investors will consider whether any business or other relationships between a portfolio manager, Bulldog Investors and a portfolio company could influence a vote on such proxy matter. With respect to personal conflicts of interest, Bulldog Investors’ Code of Ethics requires all partners to avoid activities, perquisites, gifts, or receipt of investment opportunities that could interfere with the ability to act objectively and effectively in the best interests of Bulldog Investors and its clients, and restricts their ability to engage in certain outside business activities.  Portfolio managers with a personal conflict of interest regarding a particular proxy vote must recuse themselves and not participate in the voting decisions with respect to that proxy.

Item 8. Portfolio Managers of Closed-End Management Investment Companies.

Information is presented as of January 31, 2024.

(a)(1):

The Portfolio Manager of the Fund is Bulldog Investors, LLP.  Phillip Goldstein, Andrew Dakos, and Rajeev Das are the individuals responsible for the day-to-day management of the Fund’s portfolio.  The business experience of Messrs. Goldstein, Dakos, and Das during the past 5 years is as follows:

Phillip Goldstein: Partner in Bulldog Investors, LLP and its predecessors since its inception in October 2009, and Partner of Ryan Heritage, LLP, an SEC-registered investment adviser, since its inception in 2019. Mr. Goldstein also is a member of Bulldog Holdings, LLC, the owner of several entities that previously served as the general partner of several private investment partnerships in the Bulldog Investors group of funds, and the owner of Kimball & Winthrop, LLC, the managing general partner of Bulldog Investors General Partnership, since 2012.  He is a director/trustee of the following closed-end funds: Mexico Equity and Income Fund since 2000, Swiss Helvetia Fund, Inc. since 2018 and High Income Securities Fund since 2018.  He also is a director of Brookfield DTLA Fund Office Trust Investor, a subsidiary of a large commercial real estate company, since 2017. He served as a director of MVC Capital, Inc., a business development company, from 2012-2020; and a trustee of Crossroads Liquidating Trust (f/k/a Crossroads Capital, Inc., a business development company), from 2016-2020.  Mr. Goldstein may buy and sell securities for the Fund’s portfolio without limitation.

Andrew Dakos: Partner in Bulldog Investors, LLP and its predecessors since its inception in October 2009, and Partner in Ryan Heritage, LLP, an SEC-registered investment adviser, since its inception in 2019. Mr. Dakos also is a member of Bulldog Holdings, LLC, the owner of several entities that previously served as the general partner of several private investment partnerships in the Bulldog Investors group of funds, and the owner of Kimball & Winthrop, LLC, the managing general partner of Bulldog Investors General Partnership, since 2012.  He has served as a director/trustee of Crossroads Liquidating Trust (f/k/a Crossroads Capital, Inc., a business development company), from 2015-2020, High Income Securities Fund, a closed-end fund, since 2018, Swiss Helvetia Fund, Inc., a closed-end fund, since 2017, and Brookfield DTLA Fund Office Trust Investor, a subsidiary of a large commercial real estate company, since 2017.  Mr. Dakos may buy and sell securities for the Fund’s portfolio without limitation.

Rajeev Das:  Head Trader of Bulldog Investors, LLP and its predecessors since its inception in October 2009, and Principal of Ryan Heritage, LLP, an SEC-registered investment adviser, since its inception in 2019.  Since 2004, Mr. Das has been a Principal of the entities that previously served as the general partner of the private investment partnerships in the Bulldog Investors group of investment funds.  He has been a director/trustee of the following closed-end funds: The Mexico Equity and Income Fund, Inc., since 2001; and High Income Securities Fund, since 2018.  Mr. Das provides investment research and analysis.   Mr. Das buys and sells securities for the Fund’s portfolio under the supervision of Mr. Goldstein and Mr. Dakos.

(a)(2):  Information is provided as of December 31, 2023 (per instructions to paragraph (a)(2).

(i) Phillip Goldstein, Andrew Dakos and Rajeev Das
(ii) Number of other accounts managed by Mr. Goldstein, Mr. Dakos and Mr. Das within each of the following categories:
(A) Registered investment companies:  2
(B) Other pooled investment vehicles:  6
(C) Other accounts:  337
(iii)  Number of other pooled investment vehicles, and total assets therein, with respect to which the advisory fee is based on the performance of the account: None. Number of “other accounts,” and total assets therein, with respect to which the advisory fee is based on the performance of the account:  2 other accounts; $3.03 million (estimated).

(iv) Certain conflicts of interest may arise in connection with the Portfolio Manager’s management of the Fund’s portfolio and the portfolios of other accounts managed by the investment advisor.  For example, certain inherent conflicts of interest exist in connection with managing accounts that pay a performance-based fee or allocation alongside an account that does not, and in connection with managing the accounts of certain principals of the Portfolio Manager (“Proprietary Accounts”) alongside the accounts of unaffiliated clients.  These conflicts may include an incentive to favor such accounts over the Fund because the investment advisor can potentially receive greater fees from accounts paying a performance-based fee than from the Fund.  As a result, the investment advisor may have an incentive to direct its best investment ideas to, or allocate or sequence trades in favor of such accounts, and may have an incentive to favor the Proprietary Accounts over the accounts of unaffiliated clients.  In addition, in cases where the investment strategies are the same or very similar, various factors (including, but not limited to, tax considerations, amount of available cash, and risk tolerance) may result in substantially different portfolios in such accounts. Material conflicts of interest could arise in the allocation of investment opportunities between the Fund and other accounts and pooled investment vehicles managed by Bulldog Investors, LLP and its affiliates.  In order to address these conflicts of interest, Bulldog Investors, LLP has adopted a Trade Allocation Policy which recognizes the importance of trade allocation decisions and attempts to achieve an equitable balancing of competing client interests.  The Policy establishes certain procedures to be followed in connection with placing and allocating trades for client accounts.

(a)(3):
Compensation for Messrs. Goldstein, Dakos and Das is comprised solely of net income generated by the Fund’s investment adviser.

(a)(4):  Information is provided as of December 31, 2023 (per instructions to paragraph (a)(4).

As of December 31, 2023, Mr. Goldstein beneficially owns 31,822 shares of common stock of the Registrant; Mr. Dakos beneficially owns 10,162 shares (held Directly) of common stock of the Registrant, and Indirectly owns 6,039 shares of common stock of the Registrant; and Mr. Das owns 2,583 shares of common stock of the Registrant.

Item 9. Purchases of Equity Securities by Closed‑End Management Investment Company and Affiliated Purchasers.

The following purchases were made by or on behalf of the registrant or any “affiliated purchaser,” as defined in Rule 10b-18(a)(3) under the Securities Exchange Act of 1934, as amended, of shares of the registrant’s equity securities that are registered by the Registrant pursuant to Section 12 of the Exchange Act made in the period covered by this report.

Period
(a)
Total Number of
Shares (or Units)
Purchased
(b)
Average Price Paid
per Share (or Unit)
(c)
Total Number of
Shares (or Units)
Purchased as Part
of Publicly
Announced Plans
or Programs
(d)
Maximum Number
(or Approximate
Dollar Value) of
Shares (or Units)
that May Yet Be
Purchased Under
the Plans or
Programs
7/1/2023 to
7/31/2023
82,648
 
$11.36
 
N/A
N/A
8/1/2023 to
8/31/2023
38,090
 
$11.41
 
N/A
N/A
9/1/2023 to
9/30/2023
82,541
 
$11.20
 
N/A
N/A
10/1/2023 to
10/31/2023
55,055
 
$10.60
 
N/A
N/A
11/1/2023 to
11/30/2023
53,370
 
$11.20
 
N/A
N/A
12/1/2023 to
12/31/2023
63,531
 
$11.66
 
N/A
N/A
Total
375,235(1)
$11.25
N/A
N/A

(1)  375,235 Common shares were purchased pursuant to the Fund’s Stock Repurchase Program.

Item 10. Submission of Matters to a Vote of Security Holders.

There have been no material changes to the procedures by which shareholders may recommend nominees to the registrant’s board of directors.

Item 11. Controls and Procedures.

(a)
The Registrant’s President and Chief Financial Officer have reviewed the Registrant's disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940 (the “Act”)) as of a date within 90 days of the filing of this report, as required by Rule 30a-3(b) under the Act and Rules 13a-15(b) or 15d‑15(b) under the Securities Exchange Act of 1934.  Based on their review, such officers have concluded that the disclosure controls and procedures are effective in ensuring that information required to be disclosed in this report is appropriately recorded, processed, summarized and reported and made known to them by others within the Registrant and by the Registrant’s service provider.

(b)
There were no changes in the Registrant's internal control over financial reporting (as defined in Rule 30a-3(d) under the Act) that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the Registrant's internal control over financial reporting.

Item 12. Disclosure of Securities Lending Activities for Closed-End Management Investment Companies.

The registrant did not engage in securities lending activities during the fiscal year reported on this Form N-CSR.

Item 13. Exhibits.



(3) Any written solicitation to purchase securities under Rule 23c‑1 under the Act sent or given during the period covered by the report by or on behalf of the registrant to 10 or more persons.  None.

(4) Change in the registrant’s independent public accountant.  There was no change in the registrant’s independent public accountant for the period covered by this report.






SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.


(Registrant)  Special Opportunities Fund, Inc. 

By (Signature and Title)*        /s/Andrew Dakos
Andrew Dakos, President

Date    3/4/2024



Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

By (Signature and Title)*        /s/Andrew Dakos
Andrew Dakos, President

Date    3/4/2024

By (Signature and Title)*        /s/Thomas Antonucci
Thomas Antonucci, Chief Financial Officer

Date    3/4/2024

* Print the name and title of each signing officer under his or her signature.















AMENDED AND RESTATED CODE OF ETHICS

Amended as of June 13, 2018

I.          Introduction.

 The purpose of this Amended and Restated Code of Ethics (this “Code of Ethics”) is to prevent Access Persons (as defined below) of SPECIAL OPPORTUNITIES FUND, INC. (the “Fund”) from engaging in any act, practice or course of business prohibited by paragraph (b) of Rule 17j-1 (the “Rule”) under the Investment Company Act of 1940, as amended (the “Act”).  This Code of Ethics is required by paragraph (c) of the Rule.  A copy of the Rule is available from the Fund’s Chief Compliance Officer (“CCO”) upon request.

 Access Persons of the Fund, in conducting their personal securities transactions, owe a fiduciary duty to the shareholders of the Fund.  The fundamental standard to be followed in personal securities transactions is that Access Persons may not take inappropriate advantage of their positions.  All personal securities transactions by Access Persons must be conducted in such a manner as to avoid any actual or potential conflict of interest between the Access Person’s interest and the interests of the Fund, or any abuse of an Access Person’s position of trust and responsibility.  Potential conflicts arising from personal investment activities could include buying or selling securities based on knowledge of the Fund’s trading position or plans (sometimes referred to as front-running), and acceptance of personal favors that could influence trading judgments on behalf of the Fund.  While this Code of Ethics is designed to address identified conflicts and potential conflicts, it cannot possibly be written broadly enough to cover all potential situations and, in this regard, Access Persons are expected to adhere not only to the letter, but also the spirit, of the policies contained herein.

II.          Definitions.

 In order to understand how this Code of Ethics applies to particular persons and transactions, familiarity with the key terms and concepts used in this Code of Ethics is necessary.  Those key terms and concepts are:

1. “Access Person” means any director, officer or “Advisory Person” of the Fund.

2. “Advisory Person” means (a) any employee of the Fund or of any company in a control relationship to the Fund, who, in connection with his regular functions or duties, makes, participates in, or obtains information regarding the purchase or sale of a security by the Fund, or whose functions relate to the making of any recommendations with respect to such purchases or sales; and (b) any natural person in a control relationship to the Fund who obtains information concerning recommendations made to the Fund with regard to the purchase or sale of a security.

3. “Beneficial Ownership” has the meaning set forth in Rule 16a-1(a)(2) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), a copy of which is available


from the Fund’s Compliance Officer upon request.  The determination of direct or indirect beneficial ownership shall apply to all securities which an Access Person has or acquires.

4. “Control” has the meaning set forth in Section 2(a)(9) of the Act.

5. “Independent Director” means a director of the Fund who is not an “interested person” of the Fund within the meaning of Section 2(a)(19) of the Act.

6. “Initial Public Offering” means an offering of securities registered under the Securities Act of 1933, as amended (the “Securities Act”), the issuer of which, immediately before the registration, was not subject to the reporting requirements of Section 13 or Section 15(d) of the Exchange Act.
 
 7. “Limited Offering” means an offering that is exempt from registration pursuant to Section 4(2) or Section 4(6) of the Securities Act or Rules 504, 505 or 506 of Regulation D, promulgated thereunder.
 
8. “Purchase or Sale of a Security” includes, among other things, the purchase or sale of an equivalent security, such as the writing of an option to purchase or sell a security.

9. “Security” has the meaning set forth in Section 2(a)(36) of the Act, except that it shall not include “long-term” debt securities (securities with a remaining maturity of more than 397 days) issued by the Government of the United States or “short-term” debt securities (securities with a remaining maturity of 397 days or less) issued or guaranteed as to principal or interest by the Government of the United States or by a person controlled or supervised by and acting as an instrumentality of the Government of the United States, bankers’ acceptances, bank certificates of deposit, commercial paper and shares of registered open-end investment companies.

III.          Prohibitions; Exemptions.

1.           Prohibited Purchases and Sales.

 No Access Person may purchase or sell, directly or indirectly, any security in which that Access Person has, or by reason of the transaction would acquire, any direct or indirect beneficial ownership and which to the actual knowledge of that Access Person at the time of such purchase or sale:

A. is being considered for purchase or sale by the Fund within the next fifteen (15) days; or

B. has been purchased or sold by the Fund within the previous fifteen (15) days.

If the Fund’s investment adviser determines to purchase securities of the Fund on behalf of the Fund, it will notify all Access Persons of that decision prior to any such purchase. Access Persons receiving such notice will be prohibited from the purchase or sale of Fund

2

securities until such time as the Fund’s investment adviser notifies them that it is no longer purchasing such securities.

2.           Exemptions From Certain Prohibitions.

 The prohibited purchase and sale transactions described in paragraph III.1. above do not apply to the following personal securities transactions:

 A. purchases or sales effected in any account over which the Access Person has no direct or indirect influence or control;

 B. purchases or sales which are non-volitional on the part of either the Access Person or the Fund;

 C. purchases which are part of an automatic dividend reinvestment plan (other than pursuant to a cash purchase plan option);

 D. purchases effected upon the exercise of rights issued by an issuer pro rata to all holders of a class of its securities, to the extent the rights were acquired from that issuer, and sales of the rights so acquired;

 E.               any purchase or sale, or series of related transactions, (i) with an aggregate value of $25,000 or less; or (ii) of a security with a market capitalization of greater than $5 billion; provided that, in either case, the applicable Access Person did not have actual knowledge at the time of such purchase or sale of those matters set forth in Section III.1.A. or B. above;

 F. purchases or sales of (i) “long-term” debt securities (securities with a remaining maturity of more than 397 days) issued by the U.S. Government or “short-term” debt securities (securities with a remaining maturity of 397 days or less) issued or guaranteed as to principal or interest by the U.S. Government or by a person controlled or supervised by and acting as an instrumentality of the U.S. Government, (ii) bankers’ acceptances and bank certificates of deposit, (iii) commercial paper, and (iv) shares of registered open-end investment companies (each of the foregoing being referred to herein as “Exempt Securities”);

G. any purchase or sale of a Security by an Access Person prior to which pre-clearance has been obtained from the CCO, or in the event of the CCO’s unavailability or if such purchase or sale is to be undertaken by the CCO, the Chairman of the Fund’s Audit Committee (“Audit Committee Chairman”), following a determination by the CCO or Audit Committee Chairman, as applicable, that (i) the amount or nature of the proposed purchase or sale or the person making it is not likely to affect the price or market for such Security; (ii) the person making the proposed purchase or sale is not likely to benefit from purchases or sales of the same Security being made or being considered on behalf of the Fund; and (iii) the proposed purchase or sale is not likely to adversely affect the Fund.  An Access Person seeking pre-clearance of such a purchase or sale shall submit to the CCO or Audit Committee Chairman, as applicable, the Pre-Clearance Form attached hereto as Appendix A.
 

3

 H. any purchase or sale of the Fund’s shares by an Access Person or any affiliated person of the Fund, directly or indirectly, during any time period that the Board of Directors has authorized the Fund to engage in a share buyback program provided that: (i) the Board has determined that any potential harm to the Fund is remote and (ii) proper dissemination of any material non-public information has been made on a timely basis; and

 I. any purchase or sale of the Fund’s shares by an Access Person, provided that, at the time of such purchase or sale, such Access Person is not in possession of material, non-public information concerning the Fund.  Although it is not possible to define every category of information that is material, information should be regarded as material if there is a reasonable likelihood that it would be considered important to an investor in making a decision whether to purchase or sell shares of the Fund.  For the avoidance of doubt, knowledge of the securities owned by the Fund alone shall not be considered material information.

3.           Pre-approval of Investments in IPOs and Limited Offerings.

 An Advisory Person may not purchase or otherwise acquire direct or indirect Beneficial Ownership of any Security in an Initial Public Offering or a Limited Offering unless he or she obtains pre-clearance of such purchase or acquisition from the CCO, or in the event of the CCO’s unavailability or if such purchase or acquisition is to be undertaken by the CCO, the Audit Committee Chairman.  An Advisory Person seeking pre-clearance of such purchase or acquisition shall submit to the CCO or Audit Committee Chairman, as applicable, the Pre-Clearance Form attached hereto as Appendix A.  Pre-clearance pursuant to this paragraph III.3 shall be provided by the CCO or Audit Committee Chairman, as applicable, in his or her sole discretion.
 
4.           Prohibited Recommendations.

 Subject to certain exceptions for Exempt Securities, as indicated below, an Access Person may not recommend the purchase or sale of any security to or for the Fund without having disclosed his or her interest, if any, in such security or the issuer thereof, including without limitation:

 A. any direct or indirect beneficial ownership of any security of such issuer, including any security received in a private securities transaction (other than an Exempt Security);

 B. any contemplated purchase or sale by such person of such security (other than an Exempt Security);

 C. any position with such issuer or its affiliates; and

 D. any present or proposed business relationship between such issuer or its affiliates and such person or any party in which such person has a significant interest.

IV.          Reporting and Certifications.


4

 1.            Initial Reporting and Certification.

 Within ten (10) days after a person becomes an Access Person, such person shall complete and submit to the CCO an Initial Access Person Questionnaire on the form attached as Appendix B and an Initial Holdings Report on the form attached as Appendix C.
 

 2.            Quarterly Reporting.

 A. Subject to the provisions of paragraph B below, every Access Person shall either report to the Fund the information described in paragraph C below with respect to transactions in any security in which the Access Person has, or by reason of the transaction acquires, any direct or indirect beneficial ownership in the security or, in the alternative, make the representation in paragraph D below, or by submitting a copy of the quarterly reporting form to be used in complying with this section IV, attached to this Code of Ethics as Appendix D.

 B. (1) An Access Person is not required to make a report with respect to any transaction effected for any account over which the Access Person does not have any direct or indirect influence; provided, however, that if the Access Person is relying upon the provisions of this paragraph B(1) to avoid making such a report, the Access Person shall, not later than ten (10) days after the end of each calendar quarter, identify any such account in writing and certify in writing that he or she had no direct or indirect influence over any such account.

    (2) An independent director of the Fund who would be required to make a report pursuant to paragraph A above solely by reason of being a director of the Fund is required to report a transaction in a security only if the independent director, at the time of the transaction knew or, in the ordinary course of fulfilling the independent director’s official duties as a director of the Fund, should have known that (a) the Fund has engaged in a transaction in the same security within the last fifteen (15) days or is engaging or going to engage in a transaction in the same security within the next fifteen (15) days, or (b) the Fund has within the last fifteen (15) days considered a transaction in the same security or is considering a transaction in the same security or within the next fifteen (15) days is going to consider a transaction in the same security.

 C. Every report shall be made not later than ten (10) days after the end of the calendar quarter in which the transaction to which the report relates was effected and shall contain the following information:

 (i) the date of the transaction, the title and the number of shares and the principal amount of each security involved;

 (ii) the nature of the transaction (i.e., purchase, sale or any other type of acquisition or disposition);

 (iii) the price at which the transaction was effected;


5

 (iv) the name of the broker, dealer or bank with or through whom the transaction was effected; and

 (v) a description of any factors potentially relevant to a conflict of interest analysis, including the existence of any substantial economic relationship between the transaction and securities held or to be acquired by the Fund.

 D. If no transactions were conducted by an Access Person during a calendar quarter that are subject to the reporting requirements described above, such Access Person shall, not later than ten (10) days after the end of that calendar quarter, provide a written representation to that effect to the Fund.

 3.            Annual Reporting and Certification.

 All Access Persons are required to certify annually that they have read and understand this Code of Ethics and recognize that they are subject to the provisions hereof and will comply with the policy and procedures stated herein.  Further, all Access Persons are required to certify annually that they have complied with the requirements of this Code of Ethics and that they have reported all personal securities transactions required to be disclosed or reported pursuant to the requirements of such policies.  A copy of the certification form to be used in complying with this paragraph 3 is attached to this Code of Ethics as Appendix E.

 4.            Miscellaneous.

 Any report under this Code of Ethics may contain a statement that the report shall not be construed as an admission by the person making the report that the person has any direct or indirect beneficial ownership in the securities to which the report relates.

V.           Confidentiality.

 No Access Person shall reveal to any other person (except in the normal course of his or her duties on behalf of the Fund) any information regarding securities transactions by the Fund or consideration by the Fund of any such securities transaction.

 All information obtained from any Access Person hereunder shall be kept in strict confidence, except that reports of securities transactions hereunder will be made available to the Securities and Exchange Commission or any other regulatory or self-regulatory organization to the extent required by law or regulation.

VI.           Sanctions.

 Upon discovering a violation of this Code of Ethics, the Board of Directors of the Fund may impose any sanctions it deems appropriate, including a letter of censure, the suspension or termination of any director or officer of the Fund, or the recommendation to the employer of the violator of the suspension or termination of the employment of the violator.


6

APPENDIX A

PRE-CLEARANCE FORM


ACCOUNT INFORMATION:

 
NAME OF EMPLOYEE:
 
     
 
EMPLOYEE ACCOUNT:
 
   
(Account Name & Number)
 
or
 
     
 
EMPLOYEE RELATED:
 
   
(Account Name & Number)
     
 
BROKERAGE FIRM or BANK:
 

TRANSACTION INFORMATION:

 
DATE:
         
             
 
SECURITY:
         
             
 
NUMBER OF SHARES:
         
             
 
TRADE IS TO:
BUY
   
SELL
 

 
OTHER INFORMATION:
     

 
TYPE OF ORDER:
MARKET
   
LIMIT
 

APPROVAL OF THE TRANSACTION IS SUBJECT TO YOUR KNOWLEDGE OF THE FOLLOWING INFORMATION.

1.
Is there any current order for any advisory client(s) to purchase or sell the same Security or its equivalent (the same issuer or some derivative, e.g., option or warrant)?


YES
NO

2.
Is the Security being considered for purchase or sale for any advisory client?
 
YES
NO

3.
Is the Security owned by any advisory client(s)?
YES
NO

4.
For portfolio managers, has the Security been bought or sold for advisory client account(s) within the last 15 calendar days?
 
YES
NO


A-1


5.
Do you have any material nonpublic information about the Security or the Fund?
 
YES
NO

6.
Is the Security an IPO?
YES
NO

7.
Is the Security a Limited Offering?
YES
NO

8.
Should this Security be considered an investment opportunity for clients?
 
YES
NO

9.
Has this Security been purchased or sold by you or in an account related to you in the past 60 days?
 
YES
NO

 Portfolio Managers Only (check if applicable): If I have responsibility for the determination by the Fund’s investment adviser of Securities to be purchased or sold by the Fund. I have noted (by means of an asterisk) those Securities noted above which are owned by the Fund.  If I am requesting permission to purchase Securities that are not presently owned by the Fund, I have included a statement as to why such securities are not being purchased for the Fund or being considered by the Fund.

I certify that the investment action described above is not based upon any material non-public information known to me or other inside information not generally available to the investing public.

The above information is true and correct to the best of my knowledge.

The above answers will be reviewed by the Chief Compliance Officer (or designated person).  Approval given for any transaction will remain in effect for 24 hours.


   
 
Signature
   
   
   
 
Date




APPROVED BY:
   
     
     
DATE:
   



A-2

APPENDIX B


INITIAL ACCESS PERSON QUESTIONNAIRE


1.
Name:
 


2.
Identify household members:
 
(Spouse, children, and other relatives residing in the same household)

       
       
       
       
       


3.
List all brokerage or bank accounts in which you or your immediate family members and others residing in your household have a beneficial interest and maintain accounts:

 
FIRM
 
ADDRESS
 
ACCOUNT NUMBER
           
           
           
           
           
           
           
           


4.
Do you have any outside employment or business activity?
 
YES
NO

 
If YES, Describe:
 
     
     
     


5.
Do you serve as a Director, Officer, Trustee, Member, Partner, or in any other capacity, for any other entity?
 
YES
NO



B-1


 
If YES, Describe:
 
     
     
     
     
     
     


6.
Have you received any gifts from, or made any gifts to, clients, labor union or official, or anyone else doing business with the firm, other than gifts of nominal value (defined as greater than $100)?
 
YES
NO

 
If YES, Describe:
 


7.
Have you made any charitable contributions to clients or anyone doing business with the firm in an amount greater than $1,000?
 
YES
NO

 
If YES, Describe:
 


8.
Do you own any interests in any securities or other investments not included on your brokerage statements, e.g., private placements, limited partnerships, etc. (non-custodied securities)?
 
YES
NO

 
If YES, List:
 
     
     
     


9.
Do you have any ownership interest (a minimum of 5% interest) in other entities (public or non-public) not included on brokerage statements?

 
YES
NO

 
If YES, List:
 
     
     
     



B-2


10.
Have you reviewed, understand, and agree to comply with the Code of Ethics and all current policies and procedures regarding personal securities trading and insider trading activity at our firm?

 
YES
NO




 
Signature:
 
     
 
Date:
 










B-3

APPENDIX C
 
Initial/Annual Holdings Report
 

Each Access Person is to report initially (within 10 days of becoming an Access Person) and annually thereafter (no later than January 31st of each year*) information about any security holdings in any account of the access person, or in any account in which the access person or any immediate family or household member, has a direct or indirect pecuniary interest.

The holdings information must be current within 45 days of the date of this report.

The following securities do not need to be reported under the Code of Ethics.

1.
any account in which the Funds’ investment adviser or any access person has no direct or indirect influence or control,
2.
direct obligations of the U.S. Government, e.g., U.S. Treasury bills, notes and bonds,
3.
high quality short-term instruments, e.g., U.S. bank certificates of deposit, bankers’ acceptances, and commercial paper, and money market mutual funds; and
4.
Units of unit investment trusts, so long as the unit investment trust is neither managed by our firm, any affiliate of our firm, nor invested in affiliated mutual funds.

________________________________________________
Printed Name of Access Person

Initial/Annual Holdings Information

__________     I do not have any reportable securities holdings as of:          ______________________________.
                                                              (insert date for initial report or year-end for annual report)
 


__________     I have reportable securities holdings as of:                           ______________________________.
                                                             (insert date for initial report or year-end for annual report)
 
The reportable securities holdings are listed in the:

 _____     Attached brokerage statement(s)

 _____     Attached Holdings Report, or


 _____
 I have arranged for the Firm to receive automatic duplicate confirms and statements of securities transactions and holdings which meet the reporting requirements.



     
Access Person Signature
 
Date Submitted
     
     
 
 
 
Reviewed by (CCO or designated person)
 
Date


C-1


Initial/Annual Holdings Report
Name of Security &
Ticker Symbol or CUSIP # (if applicable)
# of
Shares
Principal
Amount
Name of Broker Dealer or Bank
         
         
         
         
         
         
         
         
         
         
         
         
         
         
         
         
         
         
         
         
         
         
         
         
         
         

I certify the above/attached information is true, accurate and complete as of the date indicated and discloses all reportable securities in all accounts in which I or any household/family member have a direct or indirect beneficial interest.
 


     
Access Person Signature
 
Date Submitted
     
     
 
 
 
Reviewed by (CCO or designated person)
 
Date


Instructions:

1.
Please complete all sections;
2.
Print, sign and date the form;
3.
Send to Chief Compliance Officer (or designated person), and

C-2


4.
Send before the deadline dates noted above.






















C-3

APPENDIX D

SECURITY TRANSACTION REPORT

For the Calendar Quarter Ended __________

Instructions

1. If you are Director who is not an “interested person” of the Fund and who would be required to report solely by reason of being a Director, you need only report transactions in Covered Securities if you knew or, in the ordinary course of fulfilling your duties as a Director, you should have known that during the 15-day period immediately preceding or after the date of the transaction, such security is or was purchased or sold, or was considered for purchase or sale, by the Fund.

2. List transactions in securities (other than Exempt Securities) (“Covered Securities”) held in any account in which you may be deemed to have Beneficial Ownership as of the date indicated above. You are deemed to have Beneficial Ownership of accounts of your immediate family members.  You may exclude any of such accounts from this report, however, if you have no direct or indirect influence or control over those accounts.

3. Write “none” if you had no transactions in Covered Securities during the quarter.

4. You must submit this form within 10 days after the end of the calendar quarter.

5. If you submit copies of your monthly brokerage statements to the Fund or its designee, and those monthly brokerage statements disclose the required information with respect to all Covered Securities in which you may be deemed to have Beneficial Ownership, you need not file this form unless you established a new brokerage account during the quarter.

6. For each account that you established during the previous quarter that held securities for your direct or indirect benefit, state the name of the broker, dealer or bank with whom you established the account, the account number and the date you established the account.

Name of Security1
Date of
Transaction
Purchase/
Sale
No. of Shares or
Principal Amount
Price
Broker, Dealer
or Other Party
Through
Whom
Transaction
Was Made
             
             




1 Including interest rate and maturity, if applicable.

D-1


During the previous quarter, I established the following accounts with a broker, dealer or bank:
Broker, Dealer or Bank
Account Number
Date
Established
       
       

Certifications:  I hereby certify that:

1. The information provided above is correct.

2. This report excludes transactions with respect to which I had no direct or indirect influence or control.


Date:
 
 
Signature:
 
 
 
 
 
 
 
 
Name:
 
 
 
 
 






D-2


APPENDIX E

ANNUAL ASSET CERTIFICATION OF ACCESS PERSONS

For the Year Ended __________

Instructions

1. If you are Director who is not an “interested person” of the Fund and who would be required to report solely by reason of being a Director, you need not submit this report.

2. List each Security held in any account in which you may be deemed to have Beneficial Ownership as of the date indicated above. You are deemed to have Beneficial Ownership of accounts of your immediate family members.  You are deemed to have Beneficial Ownership of accounts of your immediate family members.  You may exclude any of such accounts from this report, however, if you have no direct or indirect influence or control over those accounts.

3. Write “none” if you did not hold any Securities at year end.

4. You must submit this form no later than January 30, _____.

5. You must complete and sign this form for annual certification whether or not you or your broker sends statements directly to the Fund or its designee.
Name of Security2
No. of Shares
or Principal
Amount
Registration on
Security or
Account
Nature of
Interest
 
Broker, Dealer
or Bank
 
           
           
           
           

Certifications:  I hereby certify that:

1. The securities listed above, or listed in the brokerage statements that I have provided, reflect all the Securities in which I may be deemed to have Beneficial Ownership at the end of the period.

2. I have read the Code of Ethics and certify that I am in compliance with it.

3. This report excludes holdings with respect to which I had no direct or indirect influence or control.


Date:
 
 
Signature:
 
 
 
 
 
 
 
 
Name:
 
 
 
 
 
 




2 Including interest rate and maturity, if applicable.


CERTIFICATIONS

I, Andrew Dakos, certify that:

 
1.
 
I have reviewed this report on Form N-CSR of Special Opportunities Fund, Inc.;
 
2.
 
Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;
 
3.
 
Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;
 
4.
 
The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:
 
(a)
 
Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;
 
(b)
 
Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;
 
(c)
 
Evaluated the effectiveness of the registrant's disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and
 
(d)
 
Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and
 
5.
 
The registrant’s other certifying officer(s) and I have disclosed to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):
 
(a)
 
All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize, and report financial information; and
 
(b)
 
Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control over financial reporting.

Date:    3/4/2024
 
/s/Andrew Dakos
Andrew Dakos
President


CERTIFICATIONS

I, Thomas Antonucci, certify that:

 
1.
 
I have reviewed this report on Form N-CSR of Special Opportunities Fund, Inc.;
 
2.
 
Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;
 
3.
 
Based on my knowledge, the financial statements, and other financial information included in this report, fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the registrant as of, and for, the periods presented in this report;
 
4.
 
The registrant’s other certifying officer(s) and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the registrant and have:
 
(a)
 
Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;
 
(b)
 
Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;
 
(c)
 
Evaluated the effectiveness of the registrant’s disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report based on such evaluation; and
 
(d)
 
Disclosed in this report any change in the registrant’s internal control over financial reporting that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting; and
 
5.
 
The registrant’s other certifying officer(s) and I have disclosed to the registrant’s auditors and the audit committee of the registrant’s board of directors (or persons performing the equivalent functions):
 
(a)
 
All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the registrant’s ability to record, process, summarize, and report financial information; and
 
(b)
 
Any fraud, whether or not material, that involves management or other employees who have a significant role in the registrant’s internal control over financial reporting.

Date:    3/4/2024
 
/s/Thomas Antonucci
Thomas Antonucci
Chief Financial Officer




Certification Pursuant to Section 906 of the Sarbanes-Oxley Act

Pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, each of the undersigned officers of the Special Opportunities Fund, Inc., does hereby certify, to such officer’s knowledge, that the report on Form N-CSR of the Special Opportunities Fund, Inc. for the year ended December 31, 2023 fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as applicable, and that the information contained in the Form N-CSR fairly presents, in all material respects, the financial condition and results of operations of the Special Opportunities Fund, Inc. for the stated period.


/s/Andrew Dakos
Andrew Dakos
President,
Special Opportunities Fund, Inc.
 
/s/Thomas Antonucci
Thomas Antonucci
Chief Financial Officer,
Special Opportunities Fund, Inc.
Dated:    3/4/2024
Dated:    3/4/2024


This statement accompanies this report on Form N-CSR pursuant to Section 906 of the Sarbanes-Oxley Act of 2002 and shall not be deemed as filed by Special Opportunities Fund, Inc. for purposes of Section 18 of the Securities Exchange Act of 1934.






Special Opportunities Fund, Inc.
January 31, 2023
19a-1 Notice

 
The Special Opportunities Fund, Inc. (the “Fund”) previously announced that the Board of Directors had approved a Managed Distribution Plan (MDP).  Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2022. On January 31, 2023, the monthly distribution under the MDP of $0.0867 per share will be paid to stockholders of record on January 20, 2023.
 
As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.
 
The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.
 
The following table sets forth an estimate of the sources of the January 31, 2023, distribution and of distributions paid in the current fiscal year:

Distribution Estimates
January 2023
Fiscal Year-to-date (YTD)1
 
Source
Per Share
Amount
Percent of
Current
Distribution
Per Share
Amount
Percent of Fiscal
Year  
Distributions
Net Investment Income
$0.0241
27.81%
$0.0241
27.81%
Net Realized Short-Term Capital Gains
$0.0000
0.00%
$0.0000
0.00%
Net Realized Long-Term Capital Gains
$0.0000
0.00%
$0.0000
0.00%
Return of Capital
$0.0626
72.19%
$0.0626
72.19%
Total Distribution
  $0.0867
100.00%
$0.0867
100.00%

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

Average Annual Total Return for the 5-year period ended on December 31, 20222
3.92%
Current Annualized Distribution Rate (current fiscal year)3
10.15%
Current Fiscal Year Cumulative Total Return4
-13.81%
Cumulative Distribution Rate (current fiscal year)5
10.15%
 
__________
 
1
The Fund’s current fiscal year began on January 1, 2023

2
Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.
 
3
The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of December 31, 2022, annualized as a percentage of the Fund’s NAV at the same date.

4
Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2022, through December 31, 2022, including distributions paid and assuming reinvestment of those distributions.
 
5
Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2022, through December 31, 2022) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of December 31, 2022.
 
You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.
 
The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.


www.specialopportunitiesfundinc.com


Special Opportunities Fund, Inc.
February 28, 2023
19a-1 Notice

 
The Special Opportunities Fund, Inc. (the “Fund”) previously announced that the Board of Directors had approved a Managed Distribution Plan (MDP).  Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2022. On February 28, 2023, the monthly distribution under the MDP of $0.0867 per share will be paid to stockholders of record on February 16, 2023.
 
As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.
 
The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.
 
The following table sets forth an estimate of the sources of the February 28, 2023, distribution and of distributions paid in the current fiscal year:

Distribution Estimates
February 2023
Fiscal Year-to-date (YTD)1
 
Source
Per Share
Amount
Percent of
Current
Distribution
Per Share
Amount
Percent of Fiscal
Year  
Distributions
Net Investment Income
$0.0425
48.99%
$0.0666
38.40%
Net Realized Short-Term Capital Gains
$0.0000
0.00%
$0.0000
0.00%
Net Realized Long-Term Capital Gains
$0.0000
0.00%
$0.0000
0.00%
Return of Capital
$0.0442
51.01%
$0.1068
61.60%
Total Distribution
  $0.0867
100.00%
$0.1734
100.00%

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

Average Annual Total Return for the 5-year period ended on January 31, 20232
4.54%
Current Annualized Distribution Rate (current fiscal year)3
7.55%
Current Fiscal Year Cumulative Total Return4
6.60%
Cumulative Distribution Rate (current fiscal year)5
0.63%
 
 __________

1
The Fund’s current fiscal year began on January 1, 2023

2
Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.
 
3
The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of January 31, 2023, annualized as a percentage of the Fund’s NAV at the same date.

4
Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2023, through January 31, 2023, including distributions paid and assuming reinvestment of those distributions.
 
5
Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2023, through January 31, 2023) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of January 31, 2023.
 
You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.
 
The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.


www.specialopportunitiesfundinc.com


Special Opportunities Fund, Inc.
March 31, 2023
19a-1 Notice

 
The Special Opportunities Fund, Inc. (the “Fund”) previously announced that the Board of Directors had approved a Managed Distribution Plan (MDP).  Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2022. On March 31, 2023, the monthly distribution under the MDP of $0.0867 per share will be paid to stockholders of record on March 22, 2023.
 
As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.
 
The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.
 
The following table sets forth an estimate of the sources of the March 31, 2023, distribution and of distributions paid in the current fiscal year:

Distribution Estimates
March 2023
Fiscal Year-to-date (YTD)1
 
Source
Per Share
Amount
Percent of
Current
Distribution
Per Share
Amount
Percent of Fiscal
Year  
Distributions
Net Investment Income
$0.0746
86.09%
$0.1412
54.30%
Net Realized Short-Term Capital Gains
$0.0063
7.29%
$0.0000
0.00%
Net Realized Long-Term Capital Gains
$0.0057
6.62%
$0.0000
0.00%
Return of Capital
$0.0000
0.00%
$0.1189
45.70%
Total Distribution
  $0.0867
100.00%
$0.2601
100.00%

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

Average Annual Total Return for the 5-year period ended on February 28, 20232
4.91%
Current Annualized Distribution Rate (current fiscal year)3
7.71%
Current Fiscal Year Cumulative Total Return4
5.09%
Cumulative Distribution Rate (current fiscal year)5
1.28%
 
__________

1
The Fund’s current fiscal year began on January 1, 2023

2
Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.
 
3
The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of January 31, 2023, annualized as a percentage of the Fund’s NAV at the same date.

4
Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2023, through February 28, 2023, including distributions paid and assuming reinvestment of those distributions.
 
5
Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2023, through February 28, 2023) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of February 28, 2023.
 
You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.
 
The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.


www.specialopportunitiesfundinc.com


Special Opportunities Fund, Inc.
April 28, 2023
19a-1 Notice

 
The Special Opportunities Fund, Inc. (the “Fund”) previously announced that the Board of Directors had approved a Managed Distribution Plan (MDP).  Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2022. On April 28, 2023, the monthly distribution under the MDP of $0.0867 per share will be paid to stockholders of record on April 19, 2023.
 
As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.
 
The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.
 
The following table sets forth an estimate of the sources of the April 28, 2023, distribution and of distributions paid in the current fiscal year:

Distribution Estimates
April 2023
Fiscal Year-to-date (YTD)1
 
Source
Per Share
Amount
Percent of
Current
Distribution
Per Share
Amount
Percent of Fiscal
Year  
Distributions
Net Investment Income
$0.0646
74.54%
$0.2059
59.36%
Net Realized Short-Term Capital Gains
$0.0031
3.53%
$0.0000
0.00%
Net Realized Long-Term Capital Gains
$0.0052
6.00%
$0.0000
0.00%
Return of Capital
$0.0.138
15.93%
$0.1409
40.64%
Total Distribution
  $0.0867
100.00%
$0.3468
100.00%

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

Average Annual Total Return for the 5-year period ended on March 31, 20232
4.70%
Current Annualized Distribution Rate (current fiscal year)3
7.85%
Current Fiscal Year Cumulative Total Return4
3.84%
Cumulative Distribution Rate (current fiscal year)5
1.96%
 
__________
 
1
The Fund’s current fiscal year began on January 1, 2023

2
Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.
 
3
The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of March 31, 2023, annualized as a percentage of the Fund’s NAV at the same date.

4
Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2023, through March 31, 2023, including distributions paid and assuming reinvestment of those distributions.
 
5
Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2023, through March 31, 2023) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of March 31, 2023.
 
You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.
 
The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.


www.specialopportunitiesfundinc.com


Special Opportunities Fund, Inc.
May 31, 2023
19a-1 Notice

 
The Special Opportunities Fund, Inc. (the “Fund”) previously announced that the Board of Directors had approved a Managed Distribution Plan (MDP).  Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2022. On May 31, 2023, the monthly distribution under the MDP of $0.0867 per share will be paid to stockholders of record on May 19, 2023.
 
As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.
 
The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.
 
The following table sets forth an estimate of the sources of the May 31, 2023, distribution and of distributions paid in the current fiscal year:

Distribution Estimates
May 2023
Fiscal Year-to-date (YTD)1
 
Source
Per Share
Amount
Percent of
Current
Distribution
Per Share
Amount
Percent of Fiscal
Year  
Distributions
Net Investment Income
$0.0618
71.23%
$0.2676
61.73%
Net Realized Short-Term Capital Gains
$0.0000
0.00%
$0.0000
0.00%
Net Realized Long-Term Capital Gains
$0.0000
0.00%
$0.0000
0.00%
Return of Capital
$0.0249
28.77%
$0.1659
38.27%
Total Distribution
  $0.0867
100.00%
$0.4335
100.00%

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

Average Annual Total Return for the 5-year period ended on April 30, 20232
4.56%
Current Annualized Distribution Rate (current fiscal year)3
7.93%
Current Fiscal Year Cumulative Total Return4
3.49%
Cumulative Distribution Rate (current fiscal year)5
2.64%
 
__________

1
The Fund’s current fiscal year began on January 1, 2023

2
Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.
 
3
The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of April 30, 2023, annualized as a percentage of the Fund’s NAV at the same date.

4
Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2023, through April 30, 2023, including distributions paid and assuming reinvestment of those distributions.
 
5
Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2023, through April 30, 2023) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of April 30, 2023.
 
You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.
 
The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.


www.specialopportunitiesfundinc.com


Special Opportunities Fund, Inc.
June 30, 2023
19a-1 Notice

 
The Special Opportunities Fund, Inc. (the “Fund”) previously announced that the Board of Directors had approved a Managed Distribution Plan (MDP).  Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2022. On June 30, 2023, the monthly distribution under the MDP of $0.0867 per share will be paid to stockholders of record on June 21, 2023.
 
As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.

The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.

The following table sets forth an estimate of the sources of the June 30, 2023, distribution and of distributions paid in the current fiscal year:

Distribution Estimates
June 2023
Fiscal Year-to-date (YTD)1
 
Source
Per Share
Amount
Percent of
Current
Distribution
Per Share
Amount
Percent of Fiscal
Year  
Distributions
Net Investment Income
$0.0867
100.00%
$0.3868
74.35%
Net Realized Short-Term Capital Gains
$0.0000
0.00%
$0.0000
0.00%
Net Realized Long-Term Capital Gains
$0.0000
0.00%
$0.0000
0.00%
Return of Capital
$0.0000
0.00%
$0.1334
25.65%
Total Distribution
  $0.0867
100.00%
$0.5202
100.00%

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

Average Annual Total Return for the 5-year period ended on May 31, 20232
4.25%
Current Annualized Distribution Rate (current fiscal year)3
8.06%
Current Fiscal Year Cumulative Total Return4
2.52%
Cumulative Distribution Rate (current fiscal year)5
3.36%
 
__________

1
The Fund’s current fiscal year began on January 1, 2023

2
Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.
 
3
The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of May 31, 2023, annualized as a percentage of the Fund’s NAV at the same date.

4
Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2023, through May 31, 2023, including distributions paid and assuming reinvestment of those distributions.
 
5
Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2023, through May 31, 2023) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of May 31, 2023.
 
You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.
 
The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.


www.specialopportunitiesfundinc.com


Special Opportunities Fund, Inc.
July 31, 2023
19a-1 Notice

 
The Special Opportunities Fund, Inc. (the “Fund”) previously announced that the Board of Directors had approved a Managed Distribution Plan (MDP).  Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2022. On July 31, 2023, the monthly distribution under the MDP of $0.0867 per share will be paid to stockholders of record on July 20, 2023.
 
As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.

The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.

The following table sets forth an estimate of the sources of the July 31, 2023, distribution and of distributions paid in the current fiscal year:

Distribution Estimates
July 2023
Fiscal Year-to-date (YTD)1
 
Source
Per Share
Amount
Percent of
Current
Distribution
Per Share
Amount
Percent of Fiscal
Year  
Distributions
Net Investment Income
$0.0685
79.02%
$0.5304
87.39%
Net Realized Short-Term Capital Gains
$0.0000
0.00%
$0.0000
0.00%
Net Realized Long-Term Capital Gains
$0.0000
0.00%
$0.0000
0.00%
Return of Capital
$0.0182
20.98%
$0.0765
12.61%
Total Distribution
  $0.0867
100.00%
$0.6069
100.00%

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

Average Annual Total Return for the 5-year period ended on June 30, 20232
5.43%
Current Annualized Distribution Rate (current fiscal year)3
7.70%
Current Fiscal Year Cumulative Total Return4
7.98%
Cumulative Distribution Rate (current fiscal year)5
3.85%
 
__________

1
The Fund’s current fiscal year began on January 1, 2023

2
Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.
 
3
The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of June 30, 2023, annualized as a percentage of the Fund’s NAV at the same date.

4
Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2023, through June 30, 2023, including distributions paid and assuming reinvestment of those distributions.
 
5
Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2023, through June 30, 2023) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of June 30, 2023.
 
You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.
 
The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.


www.specialopportunitiesfundinc.com


Special Opportunities Fund, Inc.
August 31, 2023
19a-1 Notice

 
The Special Opportunities Fund, Inc. (the “Fund”) previously announced that the Board of Directors had approved a Managed Distribution Plan (MDP).  Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2022. On August 31, 2023, the monthly distribution under the MDP of $0.0867 per share will be paid to stockholders of record on August 22, 2023.
 
As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.
 
The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.

The following table sets forth an estimate of the sources of the August 31, 2023, distribution and of distributions paid in the current fiscal year:

Distribution Estimates
August 2023
Fiscal Year-to-date (YTD)1
 
Source
Per Share
Amount
Percent of
Current
Distribution
Per Share
Amount
Percent of Fiscal
Year  
Distributions
Net Investment Income
$0.0571
65.81%
$0.5124
73.88%
Net Realized Short-Term Capital Gains
$0.0176
20.31%
$0.0000
0.00%
Net Realized Long-Term Capital Gains
$0.0000
0.00%
$0.0000
0.00%
Return of Capital
$0.0120
13.88%
$0.1812
26.12%
Total Distribution
  $0.0867
100.00%
$0.6936
100.00%

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

Average Annual Total Return for the 5-year period ended on July 31, 20232
5.98%
Current Annualized Distribution Rate (current fiscal year)3
7.46%
Current Fiscal Year Cumulative Total Return4
12.19%
Cumulative Distribution Rate (current fiscal year)5
4.35%
 
__________
 
1
The Fund’s current fiscal year began on January 1, 2023

2
Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.
 
3
The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of July 31, 2023, annualized as a percentage of the Fund’s NAV at the same date.

4
Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2023, through July 31, 2023, including distributions paid and assuming reinvestment of those distributions.
 
5
Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2023, through July 31, 2023) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of July 31, 2023.
 
You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.
 
The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.


www.specialopportunitiesfundinc.com


Special Opportunities Fund, Inc.
September 29, 2023
19a-1 Notice

 
The Special Opportunities Fund, Inc. (the “Fund”) previously announced that the Board of Directors had approved a Managed Distribution Plan (MDP).  Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2022. On September 29, 2023, the monthly distribution under the MDP of $0.0867 per share will be paid to stockholders of record on September 20, 2023.
 
As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.
 
The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.
 
The following table sets forth an estimate of the sources of the September 29, 2023, distribution and of distributions paid in the current fiscal year:

Distribution Estimates
September 2023
Fiscal Year-to-date (YTD)1
 
Source
Per Share
Amount
Percent of
Current
Distribution
Per Share
Amount
Percent of Fiscal
Year  
Distributions
Net Investment Income
$0.0867
100.00%
$0.6250
80.10%
Net Realized Short-Term Capital Gains
$0.0000
0.00%
$0.0392
5.02%
Net Realized Long-Term Capital Gains
$0.0000
0.00%
$0.0000
0.00%
Return of Capital
$0.0000
0.00%
$0.1161
14.88%
Total Distribution
  $0.0867
100.00%
$0.7803
100.00%

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

Average Annual Total Return for the 5-year period ended on August 31, 20232
5.96%
Current Annualized Distribution Rate (current fiscal year)3
7.57%
Current Fiscal Year Cumulative Total Return4
11.21%
Cumulative Distribution Rate (current fiscal year)5
5.05%
 
__________
 
1
The Fund’s current fiscal year began on January 1, 2023

2
Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.
 
3
The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of August 31, 2023, annualized as a percentage of the Fund’s NAV at the same date.

4
Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2023, through August 31, 2023, including distributions paid and assuming reinvestment of those distributions.
 
5
Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2023, through August 31, 2023) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of August 31, 2023.
 
You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.
 
The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.


www.specialopportunitiesfundinc.com


Special Opportunities Fund, Inc.
September 29, 2023
19a-1 Notice


The Special Opportunities Fund, Inc. (the “Fund”) previously announced that the Board of Directors had approved a Managed Distribution Plan (MDP).  Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2022. On October 31, 2023, the monthly distribution under the MDP of $0.0867 per share will be paid to stockholders of record on October 20, 2023.
 
As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.

The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.

The following table sets forth an estimate of the sources of the October 31, 2023, distribution and of distributions paid in the current fiscal year:

Distribution Estimates
October 2023
Fiscal Year-to-date (YTD)1
 
Source
Per Share
Amount
Percent of
Current
Distribution
Per Share
Amount
Percent of Fiscal
Year  
Distributions
Net Investment Income
$0.0555
64.05%
$0.6809
78.53%
Net Realized Short-Term Capital Gains
$0.0197
22.73%
$0.0726
8.38%
Net Realized Long-Term Capital Gains
$0.0115
13.22%
$0.0000
0.00%
Return of Capital
$0.0000
0.00%
$0.1135
13.10%
Total Distribution
  $0.0867
100.00%
$0.8671
100.00%

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

Average Annual Total Return for the 5-year period ended on September 30, 20232
5.36%
Current Annualized Distribution Rate (current fiscal year)3
7.87%
Current Fiscal Year Cumulative Total Return4
7.69%
Cumulative Distribution Rate (current fiscal year)5
5.90%
 
__________
 
1
The Fund’s current fiscal year began on January 1, 2023

2
Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.
 
3
The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of September 30, 2023, annualized as a percentage of the Fund’s NAV at the same date.

4
Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2023, through September 30, 2023, including distributions paid and assuming reinvestment of those distributions.
 
5
Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2023, through September 30, 2023) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of September 30, 2023.
 
You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.
 
The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.


www.specialopportunitiesfundinc.com


Special Opportunities Fund, Inc.
November 30, 2023
19a-1 Notice


The Special Opportunities Fund, Inc. (the “Fund”) previously announced that the Board of Directors had approved a Managed Distribution Plan (MDP).  Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2022. On November 30, 2023, the monthly distribution under the MDP of $0.0867 per share will be paid to stockholders of record on November 20, 2023.
 
As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.

The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.

The following table sets forth an estimate of the sources of the November 30, 2023, distribution and of distributions paid in the current fiscal year:

Distribution Estimates
November 2023
Fiscal Year-to-date (YTD)1
 
Source
Per Share
Amount
Percent of
Current
Distribution
Per Share
Amount
Percent of Fiscal
Year  
Distributions
Net Investment Income
$0.0867
100.00%
$0.7647
80.18%
Net Realized Short-Term Capital Gains
$0.0000
0.00%
$0.0793
8.31%
Net Realized Long-Term Capital Gains
$0.0000
0.00%
$0.0000
0.00%
Return of Capital
$0.0000
0.00%
$0.1097
11.51%
Total Distribution
  $0.0867
100.00%
$0.9537
100.00%

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

Average Annual Total Return for the 5-year period ended on October 31, 20232
6.03%
Current Annualized Distribution Rate (current fiscal year)3
8.23%
Current Fiscal Year Cumulative Total Return4
3.66%
Cumulative Distribution Rate (current fiscal year)5
6.86%
 
__________

1
The Fund’s current fiscal year began on January 1, 2023

2
Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.
 
3
The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of October 31, 2023, annualized as a percentage of the Fund’s NAV at the same date.
 
4
Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2023, through October 31, 2023, including distributions paid and assuming reinvestment of those distributions.

5
Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2023, through October 31, 2023) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of October 31, 2023.

You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.

The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.


www.specialopportunitiesfundinc.com


Special Opportunities Fund, Inc.
December 29, 2023
19a-1 Notice

 
The Special Opportunities Fund, Inc. (the “Fund”) previously announced that the Board of Directors had approved a Managed Distribution Plan (MDP).  Under the MDP, the Fund will make monthly distributions to common stockholders at an annual rate of 8% (or 0.6667% per month), based on the net asset value (NAV) of the Fund’s common shares as of December 31, 2022. On December 29, 2023, the monthly distribution under the MDP of $0.0867 per share will be paid to stockholders of record on December 19, 2023.
 
As a general matter, the amount of distributable income for each fiscal year depends on the aggregate gains and losses realized by the Fund during the entire year. Distributions may consist of net investment income, capital gains and return of capital, but the character of these distributions cannot be determined until after the end of the Fund’s fiscal year.
 
The Fund estimates that this distribution will exceed its income and capital gains; therefore, a portion of this distribution may be a return of capital. A return of capital may occur, for example, when some or all of the money that you invested in the Fund is paid back to you. A return of capital distribution does not necessarily reflect the Fund’s investment performance and should not be confused with ‘yield’ or ‘income’.

Under the Investment Company Act of 1940 (the “1940 Act”), any distribution made by an investment company, including amounts from sources other than net income must be accompanied by a written statement disclosing the source or sources of such distribution.

The following table sets forth an estimate of the sources of the December 29, 2023, distribution and of distributions paid in the current fiscal year:

Distribution Estimates
December 2023
Fiscal Year-to-date (YTD)1
 
Source
Per Share
Amount
Percent of
Current
Distribution
Per Share
Amount
Percent of Fiscal
Year  
Distributions
Net Investment Income
$0.0867
100.00%
$0.8818
84.75%
Net Realized Short-Term Capital Gains
$0.0000
0.00%
$0.0936
9.00%
Net Realized Long-Term Capital Gains
$0.0000
0.00%
$0.0000
0.00%
Return of Capital
$0.0000
0.00%
$0.0650
6.25%
Total Distribution
  $0.0867
100.00%
$1.0404
100.00%

Information regarding the Fund’s net asset performance and distribution rates is set forth below:

Average Annual Total Return for the 5-year period ended on November 30, 20232
7.65%
Current Annualized Distribution Rate (current fiscal year)3
7.56%
Current Fiscal Year Cumulative Total Return4
13.56%
Cumulative Distribution Rate (current fiscal year)5
6.93%
 
__________

1
The Fund’s current fiscal year began on January 1, 2023

2
Average annual Total Return is the percentage change in the Fund’s NAV over a year including distributions paid and assuming reinvestment of distributions.
 
3
The Current Annualized Distribution Rate is the Cumulative Distribution Rate as of November 30, 2023, annualized as a percentage of the Fund’s NAV at the same date.

4
Current Fiscal Year Cumulative Total Return is the percentage change in the Fund’s NAV from January 1, 2023, through November 30, 2023, including distributions paid and assuming reinvestment of those distributions.
 
5
Cumulative Distribution Rate for the Fund’s current fiscal period (January 1, 2023, through November 30, 2023) measured on the dollar value of distributions in the period as a percentage of the Fund’s NAV as of November 30, 2023.
 
You should not draw any conclusions about the Fund’s investment performance from the amount of this distribution or from the terms of the Fund’s MDP.
 
The amounts and sources of distributions reported above are only estimates and are not being provided for tax reporting purposes. The actual amounts and sources of the amounts for accounting and tax reporting purposes will depend upon the Fund’s investment experience during its fiscal year and may be subject to changes based on tax regulations. The Fund will send you a Form 1099-DIV for the calendar year that will tell you how to report the distribution for federal income tax purposes.

The conversion price for each share of the Fund’s convertible preferred stock will decrease by the amount of each distribution to common stockholders. The current conversion price, as well as other information about the Fund, will be available on the Fund’s website at www.specialopportunitiesfundinc.com.


www.specialopportunitiesfundinc.com





v3.24.0.1
N-2 - USD ($)
$ / shares in Units, $ in Thousands
12 Months Ended
Dec. 31, 2023
Dec. 31, 2022
Dec. 31, 2021
Dec. 31, 2020
Dec. 31, 2019
Dec. 31, 2023
Cover [Abstract]            
Entity Central Index Key           0000897802
Amendment Flag           false
Document Type           N-CSR
Entity Registrant Name           Special Opportunities Fund, Inc.
General Description of Registrant [Abstract]            
Investment Objectives and Practices [Text Block]          
Fund Investment Objective and Policies
 
The Fund investment objective is total return.  The investment objective is not fundamental and may be changed by the Board with 60 days’ notice to stockholders.  To achieve the objective, the Fund invests primarily in securities the Adviser believes have opportunities for appreciation.  The Fund may employ strategies designed to capture price movements generated by anticipated corporate events such as investing in companies involved in special situations, including, but not limited to, mergers, acquisitions, asset sales, spin-offs, balance sheet restructuring, bankruptcy, liquidations and tender offers.  In addition, the Fund may employ strategies designed to invest in the debt, equity, or trade claims of companies in financial distress when the Advisor perceives a mispricing.  Furthermore, the Fund may invest both long and short in related securities or other instruments in an effort to take advantage of perceived discrepancies in the market prices for such securities, including long and short positions in securities involved in an announced merger or acquisition.  Securities which the Adviser identifies include closed-end investment companies with opportunities for appreciation, including funds that trade at a market price discount from their NAV.  In addition to the foregoing, the Adviser seeks out other opportunities in the market that have attractive risk reward characteristics for the Fund.
 
The Fund intends its investment portfolio, under normal market conditions, to consist principally of investments in other closed-end investment companies and the securities of large, mid and small-capitalization companies, including potentially direct and indirect investments in the securities of foreign companies.  Equity securities in which the Fund may invest include common and preferred stocks, convertible securities, warrants and other securities having the characteristics of common stocks, such as ADRs and IDRs, other closed-end investment companies and exchange-traded funds. The Fund may, however, invest a portion of its assets in debt securities or other investment opportunities when the Adviser believes that it is appropriate to do so to earn current income.  For example, when interest rates are high in comparison to anticipated returns on equity investments, the Fund’s investment adviser may determine to invest in debt or preferred securities including bank, corporate or government bonds, notes, and debentures that the Adviser determines are suitable investments for the Fund.  Such determination may be made regardless of the maturity, duration or rating of any such debt security.
 
The Fund may, from time to time, engage in short sales of securities for investment or for hedging purposes.  Short sales are transactions in which the Fund sells a security it does not own.  To complete the transaction, the Fund must borrow the security to make delivery to the buyer.  The Fund is then obligated to replace the security borrowed by purchasing the security at the market price at the time of replacement.  The Fund may sell short individual stocks, baskets of
individual stocks and ETFs that the Fund expects to underperform other stocks which the Fund holds.  For hedging purposes, the Fund may purchase or sell short future contracts on global equity indexes.
 
The Fund may invest, without limitation, in the securities of closed-end funds, provided that, in accordance with Section 12(d)(1)(F) of the 1940 Act, the Fund will limit any such investment to no more than 3% of the voting stock of such fund and will vote such shares as provided in such Section as set forth below.
 
To comply with provisions of the 1940 Act, on any matter upon which stockholders of a closed-end investment company in which the Fund has invested may vote, the Adviser will direct  such shares to be voted in the same proportion as shares held by all other stockholders of such closed-end investment company (i.e., “mirror vote”) or seek instructions from the Fund’s stockholders with regard to the voting on such matter.  If the Adviser deems it appropriate to seek instructions from Fund stockholders, the Adviser will vote such proxies proportionally based upon the total number of shares owned by those shareholders that provide instructions. Fund stockholders are informed of such proxy votes on the Fund’s website and by email, if so requested, and they may provide proxy voting instructions by email.  In a letter dated August 11, 2020 discussing the results of its 2018 compliance examination, the staff of the New York regional office of the SEC’s Office of Compliance Inspections and Examinations opined that, in connection with its prior proxy voting policy, pursuant to which the Fund voted its shares of closed-end funds as determined by a majority of proxy voting instructions received, the Fund “does not in certain cases meet the requirements of the exception set forth in Section 12(d)(1)(E)(iii) of the 1940 Act because in connection with seeking instructions from Fund shareholders with regard to voting certain proxies on behalf of the Fund, the Fund votes such proxies as determined by a majority of the shares owned by those Fund shareholders who provide proxy voting instructions.”  In response thereto, the Fund has amended its proxy voting policy to provide that the Fund will vote such proxies proportionally based upon the total number of shares owned by those shareholders that provide instructions.
 
The ETFs and other closed-end investment companies in which the Fund invests may invest in common stocks and may invest in fixed income securities.  As a stockholder in any investment company, the Fund will bear its ratable share of the investment company’s expenses and would remain subject to payment of the Fund’s advisory and administrative fees with respect to the assets so invested.
 
The Fund’s management utilizes a balanced approach, including “value” and “growth” investing by seeking out companies at reasonable prices, without regard to sector or industry, which demonstrate favorable long-term growth characteristics.  Valuation and growth characteristics may be considered for purposes of selecting potential investment securities.  In general, valuation analysis is used to determine the inherent value of the company by analyzing
financial information such as a company’s price to book, price to sales, return on equity, and return on assets ratios; and growth analysis is used to determine a company’s potential for long-term dividends and earnings growth due to market-oriented factors such as growing market share, the launch of new products or services, the strength of its management and market demand.  Fluctuations in these characteristics may trigger trading decisions to be made by the Fund’s investment adviser with respect to the Fund’s portfolio.
 
Generally, securities will be purchased or sold by the Fund on national securities exchanges and in the over-the-counter market.  From time to time, securities may be purchased or sold in private transactions, including securities that are not publicly traded or that are otherwise illiquid.
 
The Fund may, from time to time, take temporary defensive positions that are inconsistent with the Fund’s principal investment strategies in attempting to respond to adverse market, economic, political or other conditions.  During such times, the Fund may temporarily invest up to 100% of its assets in cash or cash equivalents, including money market instruments, prime commercial paper, repurchase agreements, Treasury bills and other short-term obligations of the U.S. Government, its agencies or instrumentalities.  In these and in other cases, the Fund may not achieve its investment objective.
 
The Fund’s investment adviser may invest the Fund’s cash balances in any investments it deems appropriate, subject to the restrictions set forth in below under “Fundamental Investment Restrictions” and as permitted under the 1940 Act, including investments in repurchase agreements, money market funds, additional repurchase agreements, U.S. Treasury and U.S. agency securities, municipal bonds and bank accounts.  Any income earned from such investments will ordinarily be reinvested by the Fund in accordance with its investment program.  Many of the considerations entering into the Fund’s investment adviser’s recommendations and the portfolio manager’s decisions are subjective.
 
Fundamental Investment Restrictions
 
The following fundamental investment limitations cannot be changed without the affirmative vote of the lesser of (a) more than 50% of the outstanding shares of the Fund or (b) 67% or more of such shares present at a stockholders’ meeting if more than 50% of the outstanding shares are represented at the meeting in person or by proxy.  If a percentage restriction is adhered to at the time of an investment or transaction, a later increase or decrease in percentage resulting from a change in values of portfolio securities or the amount of total assets will not be considered a violation of any of the following limitations or of any of the Fund’s investment policies.  The Fund may not:
 
(1)  issue senior securities (including borrowing money from banks and other entities and thorough reverse repurchase agreements), except (a) the Fund may
borrow in an amount not in excess of 33 1/3% of total assets (including the amount of senior securities issued, but reduced by any liabilities and indebtedness not constituting senior securities), (b) the Fund may issue preferred stock having a liquidation preference in an amount which, combined with the amount of any liabilities or indebtedness constituting senior securities, is not in excess of 50% of its total assets (computed as provided in clause (a) above) and (c) the Fund may borrow up to an additional 5% of its total assets (not including the amount borrowed) for temporary or emergency purposes.
 
The following interpretation applies to, but is not a part of, fundamental limitation:
 
(1)  each state (including the District of Columbia and Puerto Rico), territory and possession of the United States, each political subdivision, agency, instrumentality and authority thereof, and each multi-state agency of which a state is a member is a separate “issuer.”  When the assets and revenues of an agency authority, instrumentality or other political subdivision are separate from the government creating the subdivision and the security is backed only by the assets and revenues of the subdivision, such subdivision would be deemed to be the sole issuer.  Similarly, in the case of an Industrial Development Bond or Private Activity Bond, if that bond is backed only by the assets and revenues of the non-governmental user, then that non-governmental user would be deemed to be the sole issuer.  However, if the creating government or another entity guarantees a security, then to the extent that the value of all securities issued or guaranteed by that government or entity and owned by the Fund exceeds 10% of the Fund’s total assets, the guarantee would be considered a separate security and would be treated as issued by that government or entity.  This restriction does not limit the percentage of the Fund’s assets that may be invested in Municipal Obligations insured by any given insurer.
 
(2)  purchase any security if, as a result of that purchase, 25% or more of the Fund’s total assets would be invested in securities of issuers having their principal business activities in the same industry, except that this limitation does not apply to securities issued or guaranteed by the U.S. government, its agencies or instrumentalities or to municipal securities.
 
(3)  make loans, except through loans of portfolio securities or through repurchase agreements, provided that for purposes of this restriction, the acquisition of bonds, debentures, other debt securities or instruments, or participations or other interests therein and investment in government obligations, commercial paper, certificates of deposit, bankers’ acceptances or similar instruments will not be considered the making of a loan.
 
(4)  engage in the business of underwriting securities of other issuers, except to the extent that the Fund might be considered an underwriter under the federal securities laws in connection with its disposition of portfolio securities.
 
(5)  purchase or sell real estate, except that investments in securities of issuers that invest in real estate and investments in mortgage-backed securities, mortgage participations or other instruments supported by interests in real estate are not subject to this limitation, and except that the Fund may exercise rights under agreements relating to such securities, including the right to enforce security interests and to hold real estate acquired by reason of such enforcement until that real estate can be liquidated in an orderly manner.
 
(6)  purchase or sell physical commodities unless acquired as a result of owning securities or other instruments, but the Fund may purchase, sell or enter into financial options and futures, forward and spot currency contracts, swap transactions and other financial contracts or derivative instruments.
 
The Fund has no intention to file a voluntary application for relief under federal bankruptcy law or any similar application under state law for so long as the Fund is solvent and does not foresee becoming insolvent.
Risk Factors [Table Text Block]          
Principal Risks Factors Related to The Fund’s Investments
 
Other Closed-End Investment Company Securities:  The Fund invests in the securities of other closed-end investment companies.  Investing in other closed-end investment companies involves substantially the same risks as investing directly in the underlying instruments, but the total return on such investments at the investment company level may be reduced by the operating expenses and fees of such other closed-end investment companies, including advisory fees.  There can be no assurance that the investment objective of any investment company in which the Fund invests will be achieved.  Closed-end investment companies are subject to the risks of investing in the underlying securities.  The Fund, as a holder of the securities of another closed-end investment company, will bear its pro rata portion of the closed-end investment company’s expenses, including advisory fees.  These expenses are in addition to the direct expenses of the Fund’s own operations.  To the extent the Fund invests a portion of its assets in investment company securities, those assets will be subject to the risks of the purchased investment company’s portfolio securities, and a stockholder in the Fund will bear not only his proportionate share of the expenses of the Fund, but also, indirectly, the expenses of the purchased investment company.  The market price of a closed-end investment company fluctuates and may be either higher or lower than the NAV of such closed-end investment company.
 
In accordance with Section 12(d)(1)(F) of the 1940 Act, the Fund will be limited by provisions of the 1940 Act that limit the amount the Fund, together with its affiliated persons, can invest in other investment companies to 3% of any other investment company’s total outstanding stock.  As a result, the Fund may hold a smaller position in a closed-end investment company than if it were not subject to this restriction.
 
Special Purpose Acquisition Companies.  The Fund may invest in units, stock, warrants, and other securities of special purpose acquisition companies or similar special purpose entities that pool funds to seek potential acquisition opportunities (“SPACs”). Unless and until an acquisition meeting the SPAC’s requirements is completed, a SPAC generally deposits substantially all of the cash raised in its IPO (less a specified amount  to cover operating expenses) in a bank trust account which is generally invested in U.S. Government securities, money market securities and cash. If an acquisition that meets the requirements for the SPAC is not completed within a pre-established period of time, the invested funds are returned to the entity’s shareholders. In addition, just prior to completion of an acquisition, shareholders of the SPAC can redeem their shares for a pro rata share of the value of the trust account.  Because SPACs have no operating history or ongoing business other than seeking acquisitions, the value of their securities can vary on the perceived likelihood of management to identify and complete a profitable acquisition. In addition, such securities are subject to secondary market risk and may decline in value if sold prior to deal completion or trust liquidation. However, until a SPAC is liquidated or completes an acquisition, its common stock is unlikely to fall substantially below the per share value of the trust account.  If an acquisition is completed, the former SPAC’s shares and other securities will take on the same risks as an equivalent investment in the acquired company.  Some SPACs may pursue acquisitions only within certain industries or regions, which may increase the volatility of their prices.
 
Short sales.  The Fund is authorized to make short sales. The Fund effects a short sale by borrowing and selling a security it does not own in anticipation of a decline in the value of the security or to hedge against the decline of a security the Fund owns. Short sales carry risks of loss if the price of the security sold short increases after the short sale. As collateral for its short positions, the Fund is required under the 1940 Act to maintain segregated assets consisting of cash, cash equivalents, or liquid securities. The amount of segregated assets is required to be adjusted daily to the extent additional collateral is required based on the change in fair value of the securities sold short.
 
Common Stocks.  The Fund invests in common stocks.  Common stocks represent an ownership interest in a company.  The Fund may also invest in securities that can be exercised for or converted into common stocks (such as convertible preferred stock).  Common stocks and similar equity securities are more volatile and riskier than some other forms of investment.  Therefore, the value of your investment in the Fund may sometimes decrease instead of increase.  Common stock prices fluctuate for many reasons, including adverse events such as unfavorable earnings reports, changes in investors’ perceptions of the financial condition of an issuer, the general condition of the relevant stock market or when political or economic events affecting the issuers occur.  In addition, common stock prices may be sensitive to rising interest rates, as the costs of capital rise and borrowing costs increase for issuers.  Because convertible securities can be
 
converted into equity securities, their values will normally increase or decrease as the values of the underlying equity securities increase or decrease.  The common stocks in which the Fund invests are structurally subordinated to preferred securities, bonds and other debt instruments in a company’s capital structure in terms of priority to corporate income and assets and, therefore, will be subject to greater risk than the preferred securities or debt instruments of such issuers.
 
Exchange Traded Funds.  The Fund may invest in exchange-traded funds, which are investment companies that, in general, aim to track or replicate a desired index, such as a sector, market or global segment.  ETFs are passively or, to a lesser extent, actively managed and their shares are traded on a national exchange.  ETFs do not sell individual shares directly to investors and only issue their shares in large blocks known as “creation units.”  The investor purchasing a creation unit may sell the individual shares on a secondary market.  Therefore, the liquidity of ETFs depends on the adequacy of the secondary market.  There can be no assurance that an ETF’s investment objective will be achieved, as ETFs based on an index may not replicate and maintain exactly the composition and relative weightings of securities in the index. ETFs are subject to the risks of investing in the underlying securities.  The Fund, as a holder of the securities of the ETF, will bear its pro rata portion of the ETF’s expenses, including advisory fees.  These expenses are in addition to the direct expenses of the Fund’s own operations. 
 
Fixed Income Securities, including Non-Investment Grade Securities.  The Fund may invest in fixed income securities, also referred to as debt securities.  Fixed income securities are subject to credit risk and market risk.  Credit risk is the risk of the issuer’s inability to meet its principal and interest payment obligations.  Market risk is the risk of price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity.  There is no limitation on the maturities or duration of fixed income securities in which the Fund invests. Securities having longer maturities generally involve greater risk of fluctuations in value resulting from changes in interest rates.  The Fund’s credit quality policy with respect to investments in fixed income securities does not require the Fund to dispose of any debt securities owned in the event that such security’s rating declines to below investment grade, commonly referred to as “junk bonds.”  Although lower quality debt typically pays a higher yield, such investments involve substantial risk of loss.  Junk bonds are considered predominantly speculative with respect to the issuer’s ability to pay interest and principal and are susceptible to default or decline in market value due to adverse economic and business developments.  The market values for junk bonds tend to be very volatile and those securities are less liquid than investment grade debt securities.  Moreover, junk bonds pose a greater risk that exercise of any of their redemption or call provisions in a declining market may result in their replacement by lower-yielding bonds.  In addition, bonds in the lowest two investment grade categories, despite being of higher credit rating than junk bonds, have speculative characteristics with respect to the issuer’s ability to pay interest and principal and their susceptibility to default or decline in market value.
 
Corporate Bonds, Government Debt Securities and Other Debt Securities:  The Fund may invest in corporate bonds, debentures and other debt securities.  Debt securities in which the Fund may invest may pay fixed or variable rates of interest. Bonds and other debt securities generally are issued by corporations and other issuers to borrow money from investors.  The issuer pays the investor a fixed or variable rate of interest and normally must repay the amount borrowed on or before maturity.  Certain debt securities are “perpetual” in that they have no maturity date.
 
The Fund may invest in government debt securities, including those of emerging market issuers or of other non-U.S. issuers.  These securities may be U.S. dollar-denominated or non-U.S. dollar-denominated and include: (a) debt obligations issued or guaranteed by foreign national, provincial, state, municipal or other governments with taxing authority or by their agencies or instrumentalities; and (b) debt obligations of supranational entities.  Government debt securities include: debt securities issued or guaranteed by governments, government agencies or instrumentalities and political subdivisions; debt securities issued by government owned, controlled or sponsored entities; interests in entities organized and operated for the purpose of restructuring the investment characteristics issued by the above noted issuers; or debt securities issued by supranational entities such as the World Bank or the European Union.  The Fund may also invest in securities denominated in currencies of emerging market countries.  Emerging market debt securities generally are rated in the lower rating categories of recognized credit rating agencies or are unrated and considered to be of comparable quality to lower rated debt securities.  A non-U.S. issuer of debt or the non-U.S. governmental authorities that control the repayment of the debt may be unable or unwilling to repay principal or interest when due, and the Fund may have limited resources in the event of a default.  Some of these risks do not apply to issuers in large, more developed countries.  These risks are more pronounced in investments in issuers in emerging markets or if the Fund invests significantly in one country.
 
Short Sale Risk:  When a cash dividend is declared on a security in which the Fund holds a short position, the Fund incurs the obligation to pay an amount equal to that dividend to the lender of the shorted security.
 
Depending on arrangements made with the broker-dealer from which it borrowed the security regarding payment over of any payments received by the Fund on such security, the Fund may not receive any payments (including interest) on its collateral deposited with such broker-dealer.
 
Although the Fund’s gain is limited to the price at which it sold the security short, its potential loss is unlimited.
Purchasing securities to close out the short position can itself cause the price of the securities to rise further, thereby exacerbating a possible loss.  Short selling exposes the Fund to unlimited risk with respect to that security due to the lack of an upper limit on the price to which an instrument can rise.
 
The requirements of the 1940 Act and Internal Revenue Code of 1986, as amended (the “Code”) provide that the Fund not make a short sale if, after giving effect to such sale, the market value of all securities sold short by the Fund exceeds 30% of the value of its managed assets.
 
Small and Medium Cap Company Risk:  Compared to investment companies that focus only on large capitalization companies, the Fund’s share price may be more volatile because it also invests in small and medium capitalization companies.  Compared to large companies, small and medium capitalization companies are more likely to have (i) more limited product lines or markets and less mature businesses, (ii) fewer capital resources, (iii) more limited management depth and (iv) shorter operating histories.  Further, compared to large cap stocks, the securities of small and medium capitalization companies are more likely to experience sharper swings in market values, be harder to sell at times and at prices that the Fund’s investment adviser believes appropriate, and offer greater potential for gains and losses.
 
Foreign Securities:  The Fund may invest in foreign securities, including direct investments in securities of foreign issuers that are traded on a U.S. securities exchange or over the counter and investments in depository receipts (such as American Depositary Receipts (“ADRs”)), ETFs and other closed-end investment companies that represent indirect interests in securities of foreign issuers.  The Fund is not limited in the amount of assets it may invest in such foreign securities.  These investments involve certain risks not generally associated with investments in the securities of U.S. issuers, including the risk of fluctuations in foreign currency exchange rates, unreliable and untimely information about the issuers and political and economic instability.  These risks could result in the Fund’s investment adviser misjudging the value of certain securities or in a significant loss in the value of those securities.
 
The value of foreign securities is affected by changes in currency rates, foreign tax laws (including withholding and confiscatory taxes), government policies (in this country or abroad), relations between nations and trading, settlement, custodial and other operational risks.  In addition, the costs of investing abroad are generally higher than in the United States, and foreign securities markets may be less liquid, more volatile and less subject to governmental supervision than markets in the U.S.  As an alternative to holding foreign traded securities, the Fund may invest in dollar-denominated securities of foreign companies that trade
on U.S. exchanges or in the U.S. over-the-counter market (including depositary receipts as described below, which evidence ownership in underlying foreign securities, and ETFs as described above).
 
Because foreign companies are not subject to uniform accounting, auditing and financial reporting standards, practices and requirements comparable to those applicable to U.S. companies, there may be less publicly available information about a foreign company than about a domestic company.  Volume and liquidity in most foreign debt markets is less than in the United States and securities of some foreign companies are less liquid and more volatile than securities of comparable U.S. companies.  There is generally less government supervision and regulation of securities exchanges, broker dealers and listed companies than in the United States.  Mail service between the United States and foreign countries may be slower or less reliable than within the United States, thus increasing the risk of delayed settlements of portfolio transactions or loss of certificates for portfolio securities.  Payment for securities before delivery may be required.  In addition, with respect to certain foreign countries, including those with emerging markets, there is the possibility of expropriation or confiscatory taxation, political or social instability, or diplomatic developments which could affect investments in those countries.  For example, prior governmental approval for foreign investments may be required in some emerging market countries, and the extent of foreign investment may be subject to limitation in other emerging countries.  Moreover, individual foreign economies may differ favorably or unfavorably from the U.S. economy in such respects as growth of gross national product, rate of inflation, capital reinvestment, resource self-sufficiency and balance of payments position.  Foreign securities markets, while growing in volume and sophistication, are generally not as developed as those in the United States, and securities of some foreign issuers (particularly those located in developing countries) may be less liquid and more volatile than securities of comparable U.S. companies.
 
The Fund may purchase ADRs, international depositary receipts (“IDRs”) and global depository receipts (“GDRs”) which are certificates evidencing ownership of shares of foreign issuers and are alternatives to purchasing directly the underlying foreign securities in their national markets and currencies.  However, such depository receipts continue to be subject to many of the risks associated with investing directly in foreign securities.  These risks include foreign exchange risk as well as the political and economic risks associated with the underlying issuer’s country. ADRs, EDRs and GDRs may be sponsored or unsponsored.  Unsponsored receipts are established without the participation of the issuer.  Unsponsored receipts may involve higher expenses, they may not pass-through voting or other stockholder rights, and they may be less liquid.  Less information is normally available on unsponsored receipts.
Dividends paid on foreign securities may not qualify for the reduced federal income tax rates applicable to qualified dividends under the Code.  As a result, there can be no assurance as to what portion of the Fund’s distributions attributable to foreign securities will be designated as qualified dividend income.
 
Emerging Market Securities:  The Fund may invest up to 5% of its net assets in emerging market securities, although through its investments in ETFs, other investment companies or depository receipts that invest in emerging market securities, up to 20% of the Fund’s assets may be invested indirectly in issuers located in emerging markets.  The risks of foreign investments described above apply to an even greater extent to investments in emerging markets.  The securities markets of emerging countries are generally smaller, less developed, less liquid, and more volatile than the securities markets of the United States and developed foreign markets.  Disclosure and regulatory standards in many respects are less stringent than in the United States and developed foreign markets.  There also may be a lower level of monitoring and regulation of securities markets in emerging market countries and the activities of investors in such markets and enforcement of existing regulations has been extremely limited.  Many emerging countries have experienced substantial, and in some periods extremely high, rates of inflation for many years.  Inflation and rapid fluctuations in inflation rates have had and may continue to have very negative effects on the economies and securities markets of certain emerging countries.  Economies in emerging markets generally are heavily dependent upon international trade and, accordingly, have been and may continue to be affected adversely by trade barriers, exchange controls, managed adjustments in relative currency values, and other protectionist measures imposed or negotiated by the countries with which they trade.  The economies of these countries also have been and may continue to be adversely affected by economic conditions in the countries in which they trade.  The economies of countries with emerging markets may also be predominantly based on only a few industries or dependent on revenues from particular commodities.  In addition, custodial services and other costs relating to investment in foreign markets may be more expensive in emerging markets than in many developed foreign markets, which could reduce the Fund’s income from such securities.  In many cases, governments of emerging countries continue to exercise significant control over their economies, and government actions relative to the economy, as well as economic developments generally, may affect the Fund’s investments in those countries.  In addition, there is a heightened possibility of expropriation or confiscatory taxation, imposition of withholding taxes on interest payments, or other similar developments that could affect investments in those countries.  There can be no assurance that adverse political changes will not cause the Fund to suffer a loss of any or all of its investments.  Dividends paid by issuers in emerging market countries will generally not qualify for the reduced federal income tax rates applicable to qualified dividends under the Code.
 
Preferred Stocks:  The Fund may invest in preferred stocks.  Preferred stock, like common stock, represents an equity ownership in an issuer.  Generally, preferred stock has a priority of claim over common stock in dividend payments and upon liquidation of the issuer. Unlike common stock, preferred stock does not usually have voting rights.  Preferred stock in some instances is convertible into common stock.  Although they are equity securities, preferred stocks have characteristics of both debt and common stock.  Like debt, their promised income is contractually fixed.  Like common stock, they do not have rights to precipitate bankruptcy proceedings or collection activities in the event of missed payments.  Other equity characteristics are their subordinated position in an issuer’s capital structure and that their quality and value are heavily dependent on the profitability of the issuer rather than on any legal claims to specific assets or cash flows.
 
Investment in preferred stocks carries risks, including credit risk, deferral risk, redemption risk, limited voting rights, risk of subordination and lack of liquidity.  Fully taxable or hybrid preferred securities typically contain provisions that allow an issuer, at its discretion, to defer distributions for up to 20 consecutive quarters.  Distributions on preferred stock must be declared by the board of directors and may be subject to deferral, and thus they may not be automatically payable.  Income payments on preferred stocks may be cumulative, causing dividends and distributions to accrue even if not declared by the company’s board or otherwise made payable, or they may be non-cumulative, so that skipped dividends and distributions do not continue to accrue.  There is no assurance that dividends on preferred stocks in which the Fund invests will be declared or otherwise made payable.  The Fund may invest in non-cumulative preferred stock, although the Fund’s investment adviser would consider, among other factors, their non-cumulative nature in making any decision to purchase or sell such securities.
 
Shares of preferred stock have a liquidation value that generally equals the original purchase price at the date of issuance.  The market values of preferred stock may be affected by favorable and unfavorable changes impacting the issuers’ industries or sectors, including companies in the utilities and financial services sectors, which are prominent issuers of preferred stock.  They may also be affected by actual and anticipated changes or ambiguities in the tax status of the security and by actual and anticipated changes or ambiguities in tax laws, such as changes in corporate and individual income tax rates, and in the dividends received deduction for corporate taxpayers or the lower rates applicable to certain dividends.
 
Because the claim on an issuer’s earnings represented by preferred stock may become onerous when interest rates fall below the rate payable on the stock or for other reasons, the issuer may redeem preferred stock, generally after an initial period of call protection in which the stock is not redeemable.  Thus, in declining interest rate environments in particular, the Fund’s holdings of higher dividend
paying preferred stocks may be reduced and the Fund may be unable to acquire securities paying comparable rates with the redemption proceeds.  In the event of a redemption, the Fund may not be able to reinvest the proceeds at comparable rates of return.
 
Convertible Securities.  The Fund may invest in convertible securities.  Convertible securities include fixed income securities that may be exchanged or converted into a predetermined number of shares of the issuer’s underlying common stock at the option of the holder during a specified period.  Convertible securities may take the form of convertible preferred stock, convertible bonds or debentures, units consisting of “usable” bonds and warrants or a combination of the features of several of these securities.  The investment characteristics of each convertible security vary widely, which allows convertible securities to be employed for a variety of investment strategies.  The Fund will exchange or convert convertible securities into shares of underlying common stock when, in the opinion of the Fund’s investment adviser, the investment characteristics of the underlying common shares will assist the Fund in achieving its investment objective.  The Fund may also elect to hold or trade convertible securities. In selecting convertible securities, the Fund’s investment adviser evaluates the investment characteristics of the convertible security as a fixed income instrument, and the investment potential of the underlying equity security for capital appreciation.  In evaluating these matters with respect to a particular convertible security, the Fund’s investment adviser considers numerous factors, including the economic and political outlook, the value of the security relative to other investment alternatives, trends in the determinants of the issuer’s profits, and the issuer’s management capability and practices.
 
The value of a convertible security, including, for example, a warrant, is a function of its “investment value” (determined by its yield in comparison with the yields of other securities of comparable maturity and quality that do not have a conversion privilege) and its “conversion value” (the security’s worth, at market value, if converted into the underlying common stock).  The investment value of a convertible security is influenced by changes in interest rates, with investment value declining as interest rates increase and increasing as interest rates decline.  The credit standing of the issuer and other factors may also have an effect on the convertible security’s investment value.  The conversion value of a convertible security is determined by the market price of the underlying common stock.  If the conversion value is low relative to the investment value, the price of the convertible security is governed principally by its investment value.  Generally, the conversion value decreases as the convertible security approaches maturity.  To the extent the market price of the underlying common stock approaches or exceeds the conversion price, the price of the convertible security will be increasingly influenced by its conversion value.  A convertible security generally will sell at a premium over its conversion value by the extent to which investors place value on
the right to acquire the underlying common stock while holding a fixed income security.  A convertible security may be subject to redemption at the option of the issuer at a price established in the convertible security’s governing instrument.  If a convertible security held by the Fund is called for redemption, the Fund will be required to permit the issuer to redeem the security, convert it into the underlying common stock or sell it to a third party.  Any of these actions could have an adverse effect on the Fund’s ability to achieve its investment objective.
 
Real Estate Investment Trusts.  The Fund may invest in real estate investment trusts (“REITs”).  REITs are financial vehicles that pool investors’ capital to purchase or finance real estate.  Investments in REITs will subject the Fund to various risks. REIT share prices may decline because of adverse developments affecting the real estate industry and real property values.  In general, real estate values can be affected by a variety of factors, including supply and demand for properties, the economic health of the country or of different regions, and the strength of specific industries that rent properties. REITs often invest in highly leveraged properties.  Returns from REITs, which typically are small or medium capitalization stocks, may trail returns from the overall stock market.  In addition, changes in interest rates may hurt real estate values or make REIT shares less attractive than other income-producing investments. REITs are also subject to heavy cash flow dependency, defaults by borrowers and self-liquidation.
 
Qualification as a REIT under the Code in any particular year is a complex analysis that depends on a number of factors.  There can be no assurance that the entities in which the Fund invests with the expectation that they will be taxed as a REIT will qualify as a REIT.  An entity that fails to qualify as a REIT would be subject to a corporate level tax, would not be entitled to a deduction for dividends paid to its stockholders and would not pass through to its stockholders the character of income earned by the entity. If the Fund were to invest in an entity that failed to qualify as a REIT, such failure could significantly reduce the Fund’s yield on that investment.
 
REITs can be classified as equity REITs, mortgage REITs and hybrid REITs.  Equity REITs invest primarily in real property and earn rental income from leasing those properties. They may also realize gains or losses from the sale of properties.  Equity REITs will be affected by conditions in the real estate rental market and by changes in the value of the properties they own.  Mortgage REITs invest primarily in mortgages and similar real estate interests and receive interest payments from the owners of the mortgaged properties.  Mortgage REITs will be affected by changes in creditworthiness of borrowers and changes in interest rates.  Hybrid REITs invest both in real property and in mortgages.  Equity and mortgage REITs are dependent upon management skills, may not be diversified and are subject to the risks of financing projects.
Dividends paid by REITs will not generally qualify for the reduced U.S. federal income tax rates applicable to qualified dividends under the Code.
 
The Fund’s investments in REITs may include an additional risk to stockholders.  Some or all of a REIT’s annual distributions to its investors may constitute a non-taxable return of capital.  Any such return of capital will generally reduce the Fund’s basis in the REIT investment, but not below zero.  To the extent the distributions from a particular REIT exceed the Fund’s basis in such REIT, the Fund will generally recognize gain.  In part because REIT distributions often include a nontaxable return of capital, trust distributions to stockholders may also include a nontaxable return of capital.  Stockholders that receive such a distribution will also reduce their tax basis in their common shares of the Fund, but not below zero.  To the extent the distribution exceeds a stockholder’s basis in the Fund’s common shares such stockholder will generally recognize a capital gain.
 
The Fund does not have any investment restrictions with respect to investments in REITs other than its concentration policy which limits its investments in REITs to no more than 25% of its assets.
 
Issuer Risk:  The value of an issuer’s securities that are held in the Fund’s portfolio may decline for a number of reasons which directly relate to the issuer, such as management performance, financial leverage and reduced demand for the issuer’s goods and services.
 
Foreign Currency Risk:  Although the Fund will report its NAV and pay expenses and distributions in U.S. dollars, the Fund may invest in foreign securities denominated or quoted in currencies other than the U.S. dollar.  Therefore, changes in foreign currency exchange rates will affect the U.S. dollar value of the Fund’s investment securities and NAV.  For example, even if the securities prices are unchanged on their primary foreign stock exchange, the Fund’s NAV may change because of a change in the rate of exchange between the U.S. dollar and the trading currency of that primary foreign stock exchange.  Certain currencies are more volatile than those of other countries and Fund investments related to those countries may be more affected.  Generally, if a foreign currency depreciates against the dollar (i.e., if the dollar strengthens), the value of the existing investment in the securities denominated in that currency will decline.  When a given currency appreciates against the dollar (i.e., if the dollar weakens), the value of the existing investment in the securities denominated in that currency will rise.  Certain foreign countries may impose restrictions on the ability of foreign securities issuers to make payments of principal and interest to investors located outside of the country, due to a blockage of foreign currency exchanges or otherwise.
 
Defensive Positions:  During periods of adverse market or economic conditions, the Fund may temporarily invest all or a substantial portion of its net assets in cash or cash equivalents.  The Fund would not be pursuing its investment objective in these circumstances and could miss favorable market developments.
 
Risk Characteristics of Options and Futures:  Options and futures transactions can be highly volatile investments. Successful hedging strategies require the anticipation of future movements in securities prices, interest rates and other economic factors. When a fund uses futures contracts and options as hedging devices, the prices of the securities subject to the futures contracts and options may not correlate with the prices of the securities in a portfolio. This may cause the futures and options to react to market changes differently than the portfolio securities. Even if expectations about the market and economic factors are correct, a hedge could be unsuccessful if changes in the value of the portfolio securities do not correspond to changes in the value of the futures contracts. The ability to establish and close out futures contracts and options on futures contracts positions depends on the availability of a secondary market. If these positions cannot be closed out due to disruptions in the market or lack of liquidity, losses may be sustained on the futures contract or option. In addition, the Fund’s use of options and futures may have the effect of reducing gains made by virtue of increases in value of the Fund’s common stock holdings.
 
Securities Lending Risk:  Securities lending is subject to the risk that loaned securities may not be available to the Fund on a timely basis and the Fund may, therefore, lose the opportunity to sell the securities at a desirable price.  Any loss in the market price of securities loaned by the Fund that occurs during the term of the loan would be borne by the Fund and would adversely affect the Fund’s performance.  Also, there may be delays in recovery, or no recovery, of securities loaned or even a loss of rights in the collateral should the borrower of the securities fail financially while the loan is outstanding. The Fund would not have the right to vote any securities having voting rights during the existence of the loan.
 
Discount Risk:  Historically, the shares of the Fund, as well as those of other closed-end investment companies, have frequently traded at a discount to their NAV. Any premium or discount to NAV often fluctuates over time. See “Price Range of Common Stock.”
 
Other Risks:  In addition to the risks detailed above, the Fund also has investments in auction rate preferred securities, business development companies, special purpose acquisition vehicles, liquidation claims, warrants and rights.  All of these other investments can subject the Fund to various risks. Any of these investments could have an adverse effect on the Fund’s ability to achieve its investment objective.
 
Investment transactions and investment income—Investment transactions are recorded on the trade date.  Realized gains and losses from investment transactions are calculated using the identified cost method.  Dividend income is recorded on the ex-dividend date.  Interest income is recorded on an accrual basis.
Discounts are accreted and premiums are amortized using the effective yield method as adjustments to interest income and the identified cost of investments.
 
Dividends and distributions—On March 4, 2019, the Fund received authorization from the U.S. Securities and Exchange Commission (the “SEC”) that permits the Fund to distribute long-term capital gains to stockholders more than once per year. Accordingly, the Board approved the implementation of a Managed Distribution Plan (“MDP”) to make monthly cash distributions to stockholders. Under the MDP, distributions will be made from current income, supplemented by realized capital gains and, to the extent necessary, paid in capital. In the year ended December 31, 2023, the Fund made monthly distributions to common stockholders at an annual rate of 8%, based on the NAV of the Fund’s common shares as of the close of business on the last business day of the previous year.  Dividends and distributions to common shareholders are recorded on the ex-dividend date.  The amount of dividends from net investment income and distributions from net realized capital gains was determined in accordance with federal income tax regulations, which may differ from U.S. generally accepted accounting principles.  These “book/tax” differences are either considered temporary or permanent in nature.  To the extent these differences are permanent in nature, such amounts are reclassified within the capital accounts based on their federal tax-basis treatment; temporary differences do not require reclassification.
 
The Fund has made certain investments in Real Estate Investment Trusts (“REITs”) which pay distributions to their shareholders based upon available funds from operations. Each REIT reports annually the tax character of its distributions. It is quite common for these distributions to exceed the REIT’s taxable earnings and profits resulting in the excess portion of such distributions being designated as a return of capital or long-term capital gain. The Fund intends to include the gross distributions from such REITs in its distributions to its shareholders; accordingly, a portion of the distributions paid to the Fund and subsequently distributed to shareholders may be re-characterized. The final determination of the amount of the Fund’s return of capital distribution for the period will be made after the end of each calendar year.
 
Holders of Convertible Preferred Stock receive calendar quarterly dividends at the rate of 2.75% of the Subscription Price per year. Dividends on the Convertible Preferred Stock are fully cumulative, and accumulate without interest from the date of original issuance of the Convertible Preferred Stock.
Capital Stock, Long-Term Debt, and Other Securities [Abstract]            
Capital Stock [Table Text Block]          
Convertible Preferred Stock
During the year ended December 31, 2021 the Fund converted 2,163,053 shares or $54,076,325 of the Fund’s Convertible Preferred Stock, Series B into 4,211,996 shares of the Fund’s common stock.  The remaining 60,923 of Convertible Preferred Shares were redeemed at $25 per share for a total of $1,523,075.
 
On January 21, 2022 the Fund completed its Convertible Preferred Rights offering at $25 per share. As a result of this offering the Fund raised $58,373,850 and issued 2,334,954 shares of 2.75% Convertible Preferred Stock, Series C. The holders of Convertible Preferred Stock, Series C may convert their shares to common stock on a quarterly basis at a conversion rate equivalent to the current conversion price of $18.250 per share of common stock (which is a current ratio of 1.3699 shares of common stock for each share of Convertible Preferred Stock, Series C held). The conversion price (and resulting conversion ratio) will be adjusted for any distributions made to or on behalf of common stockholders. Following any such conversion, shares of common stock shall be issued as soon as reasonably practicable following the next quarterly dividend payment date. Until the mandatory redemption date of the Convertible Preferred Stock, Series C, January 21, 2027, at any time following the second anniversary of the expiration date of the Convertible Preferred Stock, Series C rights offering, the Board may, in its sole discretion, redeem all or any part of the then outstanding shares of Convertible Preferred Stock, Series C at $25.00 per share. Under such circumstances, the Fund shall provide no less than 30 days’ notice to the holders of Convertible Preferred Stock, Series C that, unless such shares have been converted by a certain date, the shares will be redeemed. If, at any time from and after the date of issuance of the Convertible Preferred Stock, Series C, the market price of the common stock is equal to or greater than $21.50 per share (as adjusted for dividends or other distributions made to or on behalf of holders of the common stock), the Board may, in its sole discretion, require the holders of the Convertible Preferred Stock, Series C to convert all or any part of their shares into shares of common stock at a conversion rate equivalent to the current conversion price of $18.250 per share of common stock (which is a current ratio of 1.3699 shares of common stock for each share of Convertible Preferred Stock, Series C held), subject to adjustment upon the occurrence of certain events.
 
During the year ended December 31, 2023, the Fund purchased 80,397 shares of preferred stock in the open market at a cost of $1,830,718. The weighted average discount of these purchases comparing the average purchase price to liquidation value at the close of the New York Stock Exchange was 8.95%.
 
The conversion price (and resulting conversion ratio) will be adjusted for any dividends or other distributions made to or on behalf of common stockholders. Notice of such mandatory conversion shall be provided by the Fund in accordance with its Articles of Incorporation. In connection with all conversions shareholders of Convertible Preferred Stock would receive payment for all declared and unpaid dividends on the shares of Convertible Preferred Stock held to the date of conversion, but after conversion would no longer be entitled to the dividends, liquidation preference or other rights attributable to holders of the Convertible Preferred Stock. The Convertible Preferred Stock is classified outside of the permanent equity (net assets applicable to Common Stockholders) in the accompanying financial statements in accordance with accounting for redeemable equity instruments, which requires preferred securities that are redeemable for cash or other assets to be classified outside of permanent equity to the extent that the redemption is at a fixed or determinable price and at the option of the holder or upon occurrence of an event that is not solely within the control of the issuer. The Fund is required to meet certain asset coverage tests with respect to the Convertible Preferred Stock as required by the 1940 Act. In addition, pursuant to the Rating Agency Guidelines established by Moody’s, the Fund is required to maintain a certain discounted asset coverage. If the Fund fails to meet these requirements and does not correct such failure, the Fund may be required to redeem, in part or in full, the Convertible Preferred Stock at a redemption price of $25.00 per share, plus an amount equal to the accumulated and unpaid dividends, whether or not declared on such shares, in order to meet these requirements. Additionally, failure to meet the foregoing asset coverage requirements could restrict the Fund’s ability to pay dividends to Common Stockholders and could lead to sales of portfolio securities at inopportune times. The Fund has met these requirements since issuing the Convertible Preferred Stock.
Preferred Stock Restrictions, Other [Text Block]          
On January 21, 2022 the Fund completed its Convertible Preferred Rights offering at $25 per share. As a result of this offering the Fund raised $58,373,850 and issued 2,334,954 shares of 2.75% Convertible Preferred Stock, Series C. The holders of Convertible Preferred Stock, Series C may convert their shares to common stock on a quarterly basis at a conversion rate equivalent to the current conversion price of $18.250 per share of common stock (which is a current ratio of 1.3699 shares of common stock for each share of Convertible Preferred Stock, Series C held). The conversion price (and resulting conversion ratio) will be adjusted for any distributions made to or on behalf of common stockholders. Following any such conversion, shares of common stock shall be issued as soon as reasonably practicable following the next quarterly dividend payment date. Until the mandatory redemption date of the Convertible Preferred Stock, Series C, January 21, 2027, at any time following the second anniversary of the expiration date of the Convertible Preferred Stock, Series C rights offering, the Board may, in its sole discretion, redeem all or any part of the then outstanding shares of Convertible Preferred Stock, Series C at $25.00 per share. Under such circumstances, the Fund shall provide no less than 30 days’ notice to the holders of Convertible Preferred Stock, Series C that, unless such shares have been converted by a certain date, the shares will be redeemed. If, at any time from and after the date of issuance of the Convertible Preferred Stock, Series C, the market price of the common stock is equal to or greater than $21.50 per share (as adjusted for dividends or other distributions made to or on behalf of holders of the common stock), the Board may, in its sole discretion, require the holders of the Convertible Preferred Stock, Series C to convert all or any part of their shares into shares of common stock at a conversion rate equivalent to the current conversion price of $18.250 per share of common stock (which is a current ratio of 1.3699 shares of common stock for each share of Convertible Preferred Stock, Series C held), subject to adjustment upon the occurrence of certain events.
During the year ended December 31, 2023, the Fund purchased 80,397 shares of preferred stock in the open market at a cost of $1,830,718. The weighted average discount of these purchases comparing the average purchase price to liquidation value at the close of the New York Stock Exchange was 8.95%.
 
The conversion price (and resulting conversion ratio) will be adjusted for any dividends or other distributions made to or on behalf of common stockholders. Notice of such mandatory conversion shall be provided by the Fund in accordance with its Articles of Incorporation. In connection with all conversions shareholders of Convertible Preferred Stock would receive payment for all declared and unpaid dividends on the shares of Convertible Preferred Stock held to the date of conversion, but after conversion would no longer be entitled to the dividends, liquidation preference or other rights attributable to holders of the Convertible Preferred Stock. The Convertible Preferred Stock is classified outside of the permanent equity (net assets applicable to Common Stockholders) in the accompanying financial statements in accordance with accounting for redeemable equity instruments, which requires preferred securities that are redeemable for cash or other assets to be classified outside of permanent equity to the extent that the redemption is at a fixed or determinable price and at the option of the holder or upon occurrence of an event that is not solely within the control of the issuer. The Fund is required to meet certain asset coverage tests with respect to the Convertible Preferred Stock as required by the 1940 Act. In addition, pursuant to the Rating Agency Guidelines established by Moody’s, the Fund is required to maintain a certain discounted asset coverage. If the Fund fails to meet these requirements and does not correct such failure, the Fund may be required to redeem, in part or in full, the Convertible Preferred Stock at a redemption price of $25.00 per share, plus an amount equal to the accumulated and unpaid dividends, whether or not declared on such shares, in order to meet these requirements. Additionally, failure to meet the foregoing asset coverage requirements could restrict the Fund’s ability to pay dividends to Common Stockholders and could lead to sales of portfolio securities at inopportune times. The Fund has met these requirements since issuing the Convertible Preferred Stock.
Document Period End Date           Dec. 31, 2023
Other Closed-End Investment Company Securities [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Other Closed-End Investment Company Securities:  The Fund invests in the securities of other closed-end investment companies.  Investing in other closed-end investment companies involves substantially the same risks as investing directly in the underlying instruments, but the total return on such investments at the investment company level may be reduced by the operating expenses and fees of such other closed-end investment companies, including advisory fees.  There can be no assurance that the investment objective of any investment company in which the Fund invests will be achieved.  Closed-end investment companies are subject to the risks of investing in the underlying securities.  The Fund, as a holder of the securities of another closed-end investment company, will bear its pro rata portion of the closed-end investment company’s expenses, including advisory fees.  These expenses are in addition to the direct expenses of the Fund’s own operations.  To the extent the Fund invests a portion of its assets in investment company securities, those assets will be subject to the risks of the purchased investment company’s portfolio securities, and a stockholder in the Fund will bear not only his proportionate share of the expenses of the Fund, but also, indirectly, the expenses of the purchased investment company.  The market price of a closed-end investment company fluctuates and may be either higher or lower than the NAV of such closed-end investment company.
 
In accordance with Section 12(d)(1)(F) of the 1940 Act, the Fund will be limited by provisions of the 1940 Act that limit the amount the Fund, together with its affiliated persons, can invest in other investment companies to 3% of any other investment company’s total outstanding stock.  As a result, the Fund may hold a smaller position in a closed-end investment company than if it were not subject to this restriction.
Special Purpose Acquisition Companies [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Special Purpose Acquisition Companies.  The Fund may invest in units, stock, warrants, and other securities of special purpose acquisition companies or similar special purpose entities that pool funds to seek potential acquisition opportunities (“SPACs”). Unless and until an acquisition meeting the SPAC’s requirements is completed, a SPAC generally deposits substantially all of the cash raised in its IPO (less a specified amount  to cover operating expenses) in a bank trust account which is generally invested in U.S. Government securities, money market securities and cash. If an acquisition that meets the requirements for the SPAC is not completed within a pre-established period of time, the invested funds are returned to the entity’s shareholders. In addition, just prior to completion of an acquisition, shareholders of the SPAC can redeem their shares for a pro rata share of the value of the trust account.  Because SPACs have no operating history or ongoing business other than seeking acquisitions, the value of their securities can vary on the perceived likelihood of management to identify and complete a profitable acquisition. In addition, such securities are subject to secondary market risk and may decline in value if sold prior to deal completion or trust liquidation. However, until a SPAC is liquidated or completes an acquisition, its common stock is unlikely to fall substantially below the per share value of the trust account.  If an acquisition is completed, the former SPAC’s shares and other securities will take on the same risks as an equivalent investment in the acquired company.  Some SPACs may pursue acquisitions only within certain industries or regions, which may increase the volatility of their prices.
 
Short sales [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Short sales.  The Fund is authorized to make short sales. The Fund effects a short sale by borrowing and selling a security it does not own in anticipation of a decline in the value of the security or to hedge against the decline of a security the Fund owns. Short sales carry risks of loss if the price of the security sold short increases after the short sale. As collateral for its short positions, the Fund is required under the 1940 Act to maintain segregated assets consisting of cash, cash equivalents, or liquid securities. The amount of segregated assets is required to be adjusted daily to the extent additional collateral is required based on the change in fair value of the securities sold short.
 
Common Stocks [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Common Stocks.  The Fund invests in common stocks.  Common stocks represent an ownership interest in a company.  The Fund may also invest in securities that can be exercised for or converted into common stocks (such as convertible preferred stock).  Common stocks and similar equity securities are more volatile and riskier than some other forms of investment.  Therefore, the value of your investment in the Fund may sometimes decrease instead of increase.  Common stock prices fluctuate for many reasons, including adverse events such as unfavorable earnings reports, changes in investors’ perceptions of the financial condition of an issuer, the general condition of the relevant stock market or when political or economic events affecting the issuers occur.  In addition, common stock prices may be sensitive to rising interest rates, as the costs of capital rise and borrowing costs increase for issuers.  Because convertible securities can be
converted into equity securities, their values will normally increase or decrease as the values of the underlying equity securities increase or decrease.  The common stocks in which the Fund invests are structurally subordinated to preferred securities, bonds and other debt instruments in a company’s capital structure in terms of priority to corporate income and assets and, therefore, will be subject to greater risk than the preferred securities or debt instruments of such issuers.
Exchange Traded Funds [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Exchange Traded Funds.  The Fund may invest in exchange-traded funds, which are investment companies that, in general, aim to track or replicate a desired index, such as a sector, market or global segment.  ETFs are passively or, to a lesser extent, actively managed and their shares are traded on a national exchange.  ETFs do not sell individual shares directly to investors and only issue their shares in large blocks known as “creation units.”  The investor purchasing a creation unit may sell the individual shares on a secondary market.  Therefore, the liquidity of ETFs depends on the adequacy of the secondary market.  There can be no assurance that an ETF’s investment objective will be achieved, as ETFs based on an index may not replicate and maintain exactly the composition and relative weightings of securities in the index. ETFs are subject to the risks of investing in the underlying securities.  The Fund, as a holder of the securities of the ETF, will bear its pro rata portion of the ETF’s expenses, including advisory fees.  These expenses are in addition to the direct expenses of the Fund’s own operations. 
 
Fixed Income Securities, including Non-Investment Grade Securities [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Fixed Income Securities, including Non-Investment Grade Securities.  The Fund may invest in fixed income securities, also referred to as debt securities.  Fixed income securities are subject to credit risk and market risk.  Credit risk is the risk of the issuer’s inability to meet its principal and interest payment obligations.  Market risk is the risk of price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity.  There is no limitation on the maturities or duration of fixed income securities in which the Fund invests. Securities having longer maturities generally involve greater risk of fluctuations in value resulting from changes in interest rates.  The Fund’s credit quality policy with respect to investments in fixed income securities does not require the Fund to dispose of any debt securities owned in the event that such security’s rating declines to below investment grade, commonly referred to as “junk bonds.”  Although lower quality debt typically pays a higher yield, such investments involve substantial risk of loss.  Junk bonds are considered predominantly speculative with respect to the issuer’s ability to pay interest and principal and are susceptible to default or decline in market value due to adverse economic and business developments.  The market values for junk bonds tend to be very volatile and those securities are less liquid than investment grade debt securities.  Moreover, junk bonds pose a greater risk that exercise of any of their redemption or call provisions in a declining market may result in their replacement by lower-yielding bonds.  In addition, bonds in the lowest two investment grade categories, despite being of higher credit rating than junk bonds, have speculative characteristics with respect to the issuer’s ability to pay interest and principal and their susceptibility to default or decline in market value.
Corporate Bonds, Government Debt Securities and Other Debt Securities [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Corporate Bonds, Government Debt Securities and Other Debt Securities:  The Fund may invest in corporate bonds, debentures and other debt securities.  Debt securities in which the Fund may invest may pay fixed or variable rates of interest. Bonds and other debt securities generally are issued by corporations and other issuers to borrow money from investors.  The issuer pays the investor a fixed or variable rate of interest and normally must repay the amount borrowed on or before maturity.  Certain debt securities are “perpetual” in that they have no maturity date.
 
The Fund may invest in government debt securities, including those of emerging market issuers or of other non-U.S. issuers.  These securities may be U.S. dollar-denominated or non-U.S. dollar-denominated and include: (a) debt obligations issued or guaranteed by foreign national, provincial, state, municipal or other governments with taxing authority or by their agencies or instrumentalities; and (b) debt obligations of supranational entities.  Government debt securities include: debt securities issued or guaranteed by governments, government agencies or instrumentalities and political subdivisions; debt securities issued by government owned, controlled or sponsored entities; interests in entities organized and operated for the purpose of restructuring the investment characteristics issued by the above noted issuers; or debt securities issued by supranational entities such as the World Bank or the European Union.  The Fund may also invest in securities denominated in currencies of emerging market countries.  Emerging market debt securities generally are rated in the lower rating categories of recognized credit rating agencies or are unrated and considered to be of comparable quality to lower rated debt securities.  A non-U.S. issuer of debt or the non-U.S. governmental authorities that control the repayment of the debt may be unable or unwilling to repay principal or interest when due, and the Fund may have limited resources in the event of a default.  Some of these risks do not apply to issuers in large, more developed countries.  These risks are more pronounced in investments in issuers in emerging markets or if the Fund invests significantly in one country.
 
Short Sale Risk [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Short Sale Risk:  When a cash dividend is declared on a security in which the Fund holds a short position, the Fund incurs the obligation to pay an amount equal to that dividend to the lender of the shorted security.
 
Depending on arrangements made with the broker-dealer from which it borrowed the security regarding payment over of any payments received by the Fund on such security, the Fund may not receive any payments (including interest) on its collateral deposited with such broker-dealer.
 
Although the Fund’s gain is limited to the price at which it sold the security short, its potential loss is unlimited.
Purchasing securities to close out the short position can itself cause the price of the securities to rise further, thereby exacerbating a possible loss.  Short selling exposes the Fund to unlimited risk with respect to that security due to the lack of an upper limit on the price to which an instrument can rise.
 
The requirements of the 1940 Act and Internal Revenue Code of 1986, as amended (the “Code”) provide that the Fund not make a short sale if, after giving effect to such sale, the market value of all securities sold short by the Fund exceeds 30% of the value of its managed assets.
Small and Medium Cap Company Risk [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Small and Medium Cap Company Risk:  Compared to investment companies that focus only on large capitalization companies, the Fund’s share price may be more volatile because it also invests in small and medium capitalization companies.  Compared to large companies, small and medium capitalization companies are more likely to have (i) more limited product lines or markets and less mature businesses, (ii) fewer capital resources, (iii) more limited management depth and (iv) shorter operating histories.  Further, compared to large cap stocks, the securities of small and medium capitalization companies are more likely to experience sharper swings in market values, be harder to sell at times and at prices that the Fund’s investment adviser believes appropriate, and offer greater potential for gains and losses.
 
Foreign Securities [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Foreign Securities:  The Fund may invest in foreign securities, including direct investments in securities of foreign issuers that are traded on a U.S. securities exchange or over the counter and investments in depository receipts (such as American Depositary Receipts (“ADRs”)), ETFs and other closed-end investment companies that represent indirect interests in securities of foreign issuers.  The Fund is not limited in the amount of assets it may invest in such foreign securities.  These investments involve certain risks not generally associated with investments in the securities of U.S. issuers, including the risk of fluctuations in foreign currency exchange rates, unreliable and untimely information about the issuers and political and economic instability.  These risks could result in the Fund’s investment adviser misjudging the value of certain securities or in a significant loss in the value of those securities.
 
The value of foreign securities is affected by changes in currency rates, foreign tax laws (including withholding and confiscatory taxes), government policies (in this country or abroad), relations between nations and trading, settlement, custodial and other operational risks.  In addition, the costs of investing abroad are generally higher than in the United States, and foreign securities markets may be less liquid, more volatile and less subject to governmental supervision than markets in the U.S.  As an alternative to holding foreign traded securities, the Fund may invest in dollar-denominated securities of foreign companies that trade
on U.S. exchanges or in the U.S. over-the-counter market (including depositary receipts as described below, which evidence ownership in underlying foreign securities, and ETFs as described above).
 
Because foreign companies are not subject to uniform accounting, auditing and financial reporting standards, practices and requirements comparable to those applicable to U.S. companies, there may be less publicly available information about a foreign company than about a domestic company.  Volume and liquidity in most foreign debt markets is less than in the United States and securities of some foreign companies are less liquid and more volatile than securities of comparable U.S. companies.  There is generally less government supervision and regulation of securities exchanges, broker dealers and listed companies than in the United States.  Mail service between the United States and foreign countries may be slower or less reliable than within the United States, thus increasing the risk of delayed settlements of portfolio transactions or loss of certificates for portfolio securities.  Payment for securities before delivery may be required.  In addition, with respect to certain foreign countries, including those with emerging markets, there is the possibility of expropriation or confiscatory taxation, political or social instability, or diplomatic developments which could affect investments in those countries.  For example, prior governmental approval for foreign investments may be required in some emerging market countries, and the extent of foreign investment may be subject to limitation in other emerging countries.  Moreover, individual foreign economies may differ favorably or unfavorably from the U.S. economy in such respects as growth of gross national product, rate of inflation, capital reinvestment, resource self-sufficiency and balance of payments position.  Foreign securities markets, while growing in volume and sophistication, are generally not as developed as those in the United States, and securities of some foreign issuers (particularly those located in developing countries) may be less liquid and more volatile than securities of comparable U.S. companies.
 
The Fund may purchase ADRs, international depositary receipts (“IDRs”) and global depository receipts (“GDRs”) which are certificates evidencing ownership of shares of foreign issuers and are alternatives to purchasing directly the underlying foreign securities in their national markets and currencies.  However, such depository receipts continue to be subject to many of the risks associated with investing directly in foreign securities.  These risks include foreign exchange risk as well as the political and economic risks associated with the underlying issuer’s country. ADRs, EDRs and GDRs may be sponsored or unsponsored.  Unsponsored receipts are established without the participation of the issuer.  Unsponsored receipts may involve higher expenses, they may not pass-through voting or other stockholder rights, and they may be less liquid.  Less information is normally available on unsponsored receipts.
Dividends paid on foreign securities may not qualify for the reduced federal income tax rates applicable to qualified dividends under the Code.  As a result, there can be no assurance as to what portion of the Fund’s distributions attributable to foreign securities will be designated as qualified dividend income.
Emerging Market Securities [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Emerging Market Securities:  The Fund may invest up to 5% of its net assets in emerging market securities, although through its investments in ETFs, other investment companies or depository receipts that invest in emerging market securities, up to 20% of the Fund’s assets may be invested indirectly in issuers located in emerging markets.  The risks of foreign investments described above apply to an even greater extent to investments in emerging markets.  The securities markets of emerging countries are generally smaller, less developed, less liquid, and more volatile than the securities markets of the United States and developed foreign markets.  Disclosure and regulatory standards in many respects are less stringent than in the United States and developed foreign markets.  There also may be a lower level of monitoring and regulation of securities markets in emerging market countries and the activities of investors in such markets and enforcement of existing regulations has been extremely limited.  Many emerging countries have experienced substantial, and in some periods extremely high, rates of inflation for many years.  Inflation and rapid fluctuations in inflation rates have had and may continue to have very negative effects on the economies and securities markets of certain emerging countries.  Economies in emerging markets generally are heavily dependent upon international trade and, accordingly, have been and may continue to be affected adversely by trade barriers, exchange controls, managed adjustments in relative currency values, and other protectionist measures imposed or negotiated by the countries with which they trade.  The economies of these countries also have been and may continue to be adversely affected by economic conditions in the countries in which they trade.  The economies of countries with emerging markets may also be predominantly based on only a few industries or dependent on revenues from particular commodities.  In addition, custodial services and other costs relating to investment in foreign markets may be more expensive in emerging markets than in many developed foreign markets, which could reduce the Fund’s income from such securities.  In many cases, governments of emerging countries continue to exercise significant control over their economies, and government actions relative to the economy, as well as economic developments generally, may affect the Fund’s investments in those countries.  In addition, there is a heightened possibility of expropriation or confiscatory taxation, imposition of withholding taxes on interest payments, or other similar developments that could affect investments in those countries.  There can be no assurance that adverse political changes will not cause the Fund to suffer a loss of any or all of its investments.  Dividends paid by issuers in emerging market countries will generally not qualify for the reduced federal income tax rates applicable to qualified dividends under the Code.
Preferred Stocks [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Preferred Stocks:  The Fund may invest in preferred stocks.  Preferred stock, like common stock, represents an equity ownership in an issuer.  Generally, preferred stock has a priority of claim over common stock in dividend payments and upon liquidation of the issuer. Unlike common stock, preferred stock does not usually have voting rights.  Preferred stock in some instances is convertible into common stock.  Although they are equity securities, preferred stocks have characteristics of both debt and common stock.  Like debt, their promised income is contractually fixed.  Like common stock, they do not have rights to precipitate bankruptcy proceedings or collection activities in the event of missed payments.  Other equity characteristics are their subordinated position in an issuer’s capital structure and that their quality and value are heavily dependent on the profitability of the issuer rather than on any legal claims to specific assets or cash flows.
 
Investment in preferred stocks carries risks, including credit risk, deferral risk, redemption risk, limited voting rights, risk of subordination and lack of liquidity.  Fully taxable or hybrid preferred securities typically contain provisions that allow an issuer, at its discretion, to defer distributions for up to 20 consecutive quarters.  Distributions on preferred stock must be declared by the board of directors and may be subject to deferral, and thus they may not be automatically payable.  Income payments on preferred stocks may be cumulative, causing dividends and distributions to accrue even if not declared by the company’s board or otherwise made payable, or they may be non-cumulative, so that skipped dividends and distributions do not continue to accrue.  There is no assurance that dividends on preferred stocks in which the Fund invests will be declared or otherwise made payable.  The Fund may invest in non-cumulative preferred stock, although the Fund’s investment adviser would consider, among other factors, their non-cumulative nature in making any decision to purchase or sell such securities.
 
Shares of preferred stock have a liquidation value that generally equals the original purchase price at the date of issuance.  The market values of preferred stock may be affected by favorable and unfavorable changes impacting the issuers’ industries or sectors, including companies in the utilities and financial services sectors, which are prominent issuers of preferred stock.  They may also be affected by actual and anticipated changes or ambiguities in the tax status of the security and by actual and anticipated changes or ambiguities in tax laws, such as changes in corporate and individual income tax rates, and in the dividends received deduction for corporate taxpayers or the lower rates applicable to certain dividends.
 
Because the claim on an issuer’s earnings represented by preferred stock may become onerous when interest rates fall below the rate payable on the stock or for other reasons, the issuer may redeem preferred stock, generally after an initial period of call protection in which the stock is not redeemable.  Thus, in declining interest rate environments in particular, the Fund’s holdings of higher dividend
paying preferred stocks may be reduced and the Fund may be unable to acquire securities paying comparable rates with the redemption proceeds.  In the event of a redemption, the Fund may not be able to reinvest the proceeds at comparable rates of return.
Convertible Securities [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Convertible Securities.  The Fund may invest in convertible securities.  Convertible securities include fixed income securities that may be exchanged or converted into a predetermined number of shares of the issuer’s underlying common stock at the option of the holder during a specified period.  Convertible securities may take the form of convertible preferred stock, convertible bonds or debentures, units consisting of “usable” bonds and warrants or a combination of the features of several of these securities.  The investment characteristics of each convertible security vary widely, which allows convertible securities to be employed for a variety of investment strategies.  The Fund will exchange or convert convertible securities into shares of underlying common stock when, in the opinion of the Fund’s investment adviser, the investment characteristics of the underlying common shares will assist the Fund in achieving its investment objective.  The Fund may also elect to hold or trade convertible securities. In selecting convertible securities, the Fund’s investment adviser evaluates the investment characteristics of the convertible security as a fixed income instrument, and the investment potential of the underlying equity security for capital appreciation.  In evaluating these matters with respect to a particular convertible security, the Fund’s investment adviser considers numerous factors, including the economic and political outlook, the value of the security relative to other investment alternatives, trends in the determinants of the issuer’s profits, and the issuer’s management capability and practices.
 
The value of a convertible security, including, for example, a warrant, is a function of its “investment value” (determined by its yield in comparison with the yields of other securities of comparable maturity and quality that do not have a conversion privilege) and its “conversion value” (the security’s worth, at market value, if converted into the underlying common stock).  The investment value of a convertible security is influenced by changes in interest rates, with investment value declining as interest rates increase and increasing as interest rates decline.  The credit standing of the issuer and other factors may also have an effect on the convertible security’s investment value.  The conversion value of a convertible security is determined by the market price of the underlying common stock.  If the conversion value is low relative to the investment value, the price of the convertible security is governed principally by its investment value.  Generally, the conversion value decreases as the convertible security approaches maturity.  To the extent the market price of the underlying common stock approaches or exceeds the conversion price, the price of the convertible security will be increasingly influenced by its conversion value.  A convertible security generally will sell at a premium over its conversion value by the extent to which investors place value on
the right to acquire the underlying common stock while holding a fixed income security.  A convertible security may be subject to redemption at the option of the issuer at a price established in the convertible security’s governing instrument.  If a convertible security held by the Fund is called for redemption, the Fund will be required to permit the issuer to redeem the security, convert it into the underlying common stock or sell it to a third party.  Any of these actions could have an adverse effect on the Fund’s ability to achieve its investment objective.
Real Estate Investment Trusts [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Real Estate Investment Trusts.  The Fund may invest in real estate investment trusts (“REITs”).  REITs are financial vehicles that pool investors’ capital to purchase or finance real estate.  Investments in REITs will subject the Fund to various risks. REIT share prices may decline because of adverse developments affecting the real estate industry and real property values.  In general, real estate values can be affected by a variety of factors, including supply and demand for properties, the economic health of the country or of different regions, and the strength of specific industries that rent properties. REITs often invest in highly leveraged properties.  Returns from REITs, which typically are small or medium capitalization stocks, may trail returns from the overall stock market.  In addition, changes in interest rates may hurt real estate values or make REIT shares less attractive than other income-producing investments. REITs are also subject to heavy cash flow dependency, defaults by borrowers and self-liquidation.
 
Qualification as a REIT under the Code in any particular year is a complex analysis that depends on a number of factors.  There can be no assurance that the entities in which the Fund invests with the expectation that they will be taxed as a REIT will qualify as a REIT.  An entity that fails to qualify as a REIT would be subject to a corporate level tax, would not be entitled to a deduction for dividends paid to its stockholders and would not pass through to its stockholders the character of income earned by the entity. If the Fund were to invest in an entity that failed to qualify as a REIT, such failure could significantly reduce the Fund’s yield on that investment.
 
REITs can be classified as equity REITs, mortgage REITs and hybrid REITs.  Equity REITs invest primarily in real property and earn rental income from leasing those properties. They may also realize gains or losses from the sale of properties.  Equity REITs will be affected by conditions in the real estate rental market and by changes in the value of the properties they own.  Mortgage REITs invest primarily in mortgages and similar real estate interests and receive interest payments from the owners of the mortgaged properties.  Mortgage REITs will be affected by changes in creditworthiness of borrowers and changes in interest rates.  Hybrid REITs invest both in real property and in mortgages.  Equity and mortgage REITs are dependent upon management skills, may not be diversified and are subject to the risks of financing projects.
Dividends paid by REITs will not generally qualify for the reduced U.S. federal income tax rates applicable to qualified dividends under the Code.
 
The Fund’s investments in REITs may include an additional risk to stockholders.  Some or all of a REIT’s annual distributions to its investors may constitute a non-taxable return of capital.  Any such return of capital will generally reduce the Fund’s basis in the REIT investment, but not below zero.  To the extent the distributions from a particular REIT exceed the Fund’s basis in such REIT, the Fund will generally recognize gain.  In part because REIT distributions often include a nontaxable return of capital, trust distributions to stockholders may also include a nontaxable return of capital.  Stockholders that receive such a distribution will also reduce their tax basis in their common shares of the Fund, but not below zero.  To the extent the distribution exceeds a stockholder’s basis in the Fund’s common shares such stockholder will generally recognize a capital gain.
 
The Fund does not have any investment restrictions with respect to investments in REITs other than its concentration policy which limits its investments in REITs to no more than 25% of its assets.
Issuer Risk [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Issuer Risk:  The value of an issuer’s securities that are held in the Fund’s portfolio may decline for a number of reasons which directly relate to the issuer, such as management performance, financial leverage and reduced demand for the issuer’s goods and services.
 
Foreign Currency Risk [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Foreign Currency Risk:  Although the Fund will report its NAV and pay expenses and distributions in U.S. dollars, the Fund may invest in foreign securities denominated or quoted in currencies other than the U.S. dollar.  Therefore, changes in foreign currency exchange rates will affect the U.S. dollar value of the Fund’s investment securities and NAV.  For example, even if the securities prices are unchanged on their primary foreign stock exchange, the Fund’s NAV may change because of a change in the rate of exchange between the U.S. dollar and the trading currency of that primary foreign stock exchange.  Certain currencies are more volatile than those of other countries and Fund investments related to those countries may be more affected.  Generally, if a foreign currency depreciates against the dollar (i.e., if the dollar strengthens), the value of the existing investment in the securities denominated in that currency will decline.  When a given currency appreciates against the dollar (i.e., if the dollar weakens), the value of the existing investment in the securities denominated in that currency will rise.  Certain foreign countries may impose restrictions on the ability of foreign securities issuers to make payments of principal and interest to investors located outside of the country, due to a blockage of foreign currency exchanges or otherwise.
 
Defensive Positions [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Defensive Positions:  During periods of adverse market or economic conditions, the Fund may temporarily invest all or a substantial portion of its net assets in cash or cash equivalents.  The Fund would not be pursuing its investment objective in these circumstances and could miss favorable market developments.
Risk Characteristics of Options and Futures [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Risk Characteristics of Options and Futures:  Options and futures transactions can be highly volatile investments. Successful hedging strategies require the anticipation of future movements in securities prices, interest rates and other economic factors. When a fund uses futures contracts and options as hedging devices, the prices of the securities subject to the futures contracts and options may not correlate with the prices of the securities in a portfolio. This may cause the futures and options to react to market changes differently than the portfolio securities. Even if expectations about the market and economic factors are correct, a hedge could be unsuccessful if changes in the value of the portfolio securities do not correspond to changes in the value of the futures contracts. The ability to establish and close out futures contracts and options on futures contracts positions depends on the availability of a secondary market. If these positions cannot be closed out due to disruptions in the market or lack of liquidity, losses may be sustained on the futures contract or option. In addition, the Fund’s use of options and futures may have the effect of reducing gains made by virtue of increases in value of the Fund’s common stock holdings.
 
Securities Lending Risk [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Securities Lending Risk:  Securities lending is subject to the risk that loaned securities may not be available to the Fund on a timely basis and the Fund may, therefore, lose the opportunity to sell the securities at a desirable price.  Any loss in the market price of securities loaned by the Fund that occurs during the term of the loan would be borne by the Fund and would adversely affect the Fund’s performance.  Also, there may be delays in recovery, or no recovery, of securities loaned or even a loss of rights in the collateral should the borrower of the securities fail financially while the loan is outstanding. The Fund would not have the right to vote any securities having voting rights during the existence of the loan.
 
Discount Risk [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Discount Risk:  Historically, the shares of the Fund, as well as those of other closed-end investment companies, have frequently traded at a discount to their NAV. Any premium or discount to NAV often fluctuates over time. See “Price Range of Common Stock.”
 
Other Risks [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Other Risks:  In addition to the risks detailed above, the Fund also has investments in auction rate preferred securities, business development companies, special purpose acquisition vehicles, liquidation claims, warrants and rights.  All of these other investments can subject the Fund to various risks. Any of these investments could have an adverse effect on the Fund’s ability to achieve its investment objective.
 
Investment transactions and investment income [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Investment transactions and investment income—Investment transactions are recorded on the trade date.  Realized gains and losses from investment transactions are calculated using the identified cost method.  Dividend income is recorded on the ex-dividend date.  Interest income is recorded on an accrual basis.
Discounts are accreted and premiums are amortized using the effective yield method as adjustments to interest income and the identified cost of investments.
Dividends and distributions [Member]            
General Description of Registrant [Abstract]            
Risk [Text Block]          
Dividends and distributions—On March 4, 2019, the Fund received authorization from the U.S. Securities and Exchange Commission (the “SEC”) that permits the Fund to distribute long-term capital gains to stockholders more than once per year. Accordingly, the Board approved the implementation of a Managed Distribution Plan (“MDP”) to make monthly cash distributions to stockholders. Under the MDP, distributions will be made from current income, supplemented by realized capital gains and, to the extent necessary, paid in capital. In the year ended December 31, 2023, the Fund made monthly distributions to common stockholders at an annual rate of 8%, based on the NAV of the Fund’s common shares as of the close of business on the last business day of the previous year.  Dividends and distributions to common shareholders are recorded on the ex-dividend date.  The amount of dividends from net investment income and distributions from net realized capital gains was determined in accordance with federal income tax regulations, which may differ from U.S. generally accepted accounting principles.  These “book/tax” differences are either considered temporary or permanent in nature.  To the extent these differences are permanent in nature, such amounts are reclassified within the capital accounts based on their federal tax-basis treatment; temporary differences do not require reclassification.
 
The Fund has made certain investments in Real Estate Investment Trusts (“REITs”) which pay distributions to their shareholders based upon available funds from operations. Each REIT reports annually the tax character of its distributions. It is quite common for these distributions to exceed the REIT’s taxable earnings and profits resulting in the excess portion of such distributions being designated as a return of capital or long-term capital gain. The Fund intends to include the gross distributions from such REITs in its distributions to its shareholders; accordingly, a portion of the distributions paid to the Fund and subsequently distributed to shareholders may be re-characterized. The final determination of the amount of the Fund’s return of capital distribution for the period will be made after the end of each calendar year.
 
Holders of Convertible Preferred Stock receive calendar quarterly dividends at the rate of 2.75% of the Subscription Price per year. Dividends on the Convertible Preferred Stock are fully cumulative, and accumulate without interest from the date of original issuance of the Convertible Preferred Stock.
Common Shares [Member]            
General Description of Registrant [Abstract]            
Share Price $ 11.86 $ 11.40 $ 15.45 $ 14.08 $ 14.73 $ 11.86
NAV Per Share $ 14.30 $ 13.01 $ 16.55 $ 16.13 $ 16.06 $ 14.30
Capital Stock, Long-Term Debt, and Other Securities [Abstract]            
Outstanding Security, Title [Text Block] Common stock          
Outstanding Security, Authorized [Shares] 199,995,800          
Outstanding Security, Held [Shares] 14,796,650          
Outstanding Security, Not Held [Shares] 11,010,177          
Preferred Shares [Member]            
Financial Highlights [Abstract]            
Senior Securities Amount $ 56,364 $ 58,374 $ 55,599 $ 55,599 $ 56,364
Senior Securities Coverage per Unit $ 95 $ 89 $ 87 $ 86 $ 95
Preferred Stock Liquidating Preference $ 25         $ 25
Capital Stock, Long-Term Debt, and Other Securities [Abstract]            
Outstanding Security, Title [Text Block] 2.75% Convertible Preferred Stock          
Outstanding Security, Not Held [Shares] 2,254,557 2,334,954 2,223,976 2,223,976  

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