That won't satisfy the tax law requirements. Understand that the REIT tax laws DON'T stipulate that a company has to pay a special dividend. They stipulate that if there are retained earnings they must be paid out to the extent that they are taken to zero. Issuing additional stock does not reduce retaining earnings. Retained Earnings are reduced either by dividend payments or incurring losses.
The above is my understanding anyway. I'm not a CPA or Tax Attorney.