Riddle me this: What does a dividend-gushing REIT have in common with cloud computing and mobile video?

The answer is cell tower builder and operator American Tower (NYSE: AMT). The company is planning to become a real estate investment trust for tax purposes, which is a unique idea for a business with the high-growth mojo of a technology infrastructure giant.

Paying out 90% of American Tower's operating income as dividends, which is what REITs must do in exchange for a favorable tax rate, would have meant $551 million of distributions over the last year. That would translate into $1.37 per share, or a 2.6% yield at today's prices.

While a far cry from the double-digit dividend yields of traditional REIT titans Chimera Investment (NYSE: CIM) or American Capital Agency (Nasdaq: AGNC), that's not too shabby for a company that never paid a dividend in its life. Being a real-estate play that also happens to run a mobile communications racket, American Tower is also following in the footsteps of McDonald's (NYSE: MCD), which always was a real estate company that happens to sell hamburgers.

McDonald's has considered going the REIT route many times but ultimately rejected the idea. American Tower is definitely going there.

The company reported first-quarter sales of $563 million, 24% above the year-ago period, driven by international expansion. Operating income jumped 22% to $218 million, but the tax man wanted a bigger slice of that pie, so earnings swooned 4.2% to $0.23 per share. This is where a REIT's tax saving would come in handy.

And the process is moving along. American Tower took the opportunity to announce a favorable private letter ruling from the IRS, which removes one of many hurdles from the application process.

Management takes pains to note that its board of directors may decide to drop the REIT idea in the end, and that the REIT conversion wouldn't happen until the start of 2012. But after all the due diligence prep work, not to mention the obvious tax benefits of following through, I'd be shocked to see the IRS approving American Tower's REIT application for naught. It just won't happen.

So here's a hidden dividend stock in the making, and it taps into at least two of the most exciting growth trends of our time. How many cloud-computing plays can you name that also pay a serious dividend? No wonder we call American Tower a Rule Breaker.