ICI Submits Comment Letter on IRS Form 8613 (pdf)

By Electronic Delivery April 2, 2019 Laurie Brimmer Internal Revenue Service, Rm 6529 1111 Constitution Avenue NW Washington, DC 20224 RE: ICI Comments to IRS Form 8613 Dear Ms. Brimmer: The Investment Company Institute1 appreciates the opportunity to offer comments on Internal Revenue Service (IRS) Form 8613 “Return of Excise Tax on Undistributed Income of Regulated Investment Companies.”2 IRS Form 8613 is used by regulated investment companies (RICs) to compute and pay the excise tax on undistributed income imposed under Internal Revenue Code Section 4982. The Institute believes that the recommendations below are consistent with the IRS’s continuing effort to reduce paperwork and taxpayer burden.  Information Only Filers. We recommend that Form 8613 include a check box to indicate when the form is filed only for informational purposes. This change would benefit RICs that are not required to file Form 8613, such as those exempt under section 4982(f), but that routinely do so for informational purposes. As these exempt funds sometimes receive notices of underpayment in response to the filing, the change would prevent the IRS from issuing unnecessary underpayment notices. 1 The Investment Company Institute (ICI) is the leading association representing regulated funds globally, including mutual funds, exchange-traded funds (ETFs), closed-end funds, and unit investment trusts (UITs) in the United States, and similar funds offered to investors in jurisdictions worldwide. ICI seeks to encourage adherence to high ethical standards, promote public understanding, and otherwise advance the interests of funds, their shareholders, directors, and advisers. ICI’s members manage total assets of US$22.4 trillion in the United States, serving more than 100 million US shareholders, and US$6.6 trillion in assets in other jurisdictions. ICI carries out its international work through ICI Global, with offices in London, Hong Kong, and Washington, DC. 2 See Internal Revenue Service, Notice, Comment Request for Form 8613, published February 1, 2019, Federal Register Vol. 84, No. 22. ICI Comments to IRS Form 8613 April 2, 2019 Page 2 of 2  4982(e)(7) Election. We recommend that the section 4982(e)(7) election be incorporated as a check box election, with the amount of the deferral disclosed on an additional line item on Form 8613. This change would eliminate the need for an additional statement disclosure. * * * If we can provide you with any additional information regarding these comments, please contact me at 202-326-5826 or katie.sunderland@ici.org. Sincerely, Katie Sunderland Assistant General Counsel – Tax Law