July 26, 1989
TO: TAX COMMITTEE NO. 11-89
UNIT INVESTMENT TRUST COMMITTEE NO. 38-89
CLOSED-END FUND COMMITTEE NO. 29-89
OPERATIONS COMMITTEE NO. 12-89
TRANSFER AGENT SHAREHOLDER ADVISORY COMMITTEE NO. 19-89
RE: INSTITUTE REQUEST TO POSTPONE B NOTICES
__________________________________________________________
As we previously informed you, last month the Institute
filed with the IRS a letter commenting on recent amendments to
the backup withholding and due diligence regulations and raising
once again our principal concerns with these requirements. (See
Institute Memorandum to Tax Committee No. 10-89, Unit Investment
Trust Committee No. 27-89, Closed-End Fund Committee No. 20-89,
Operations Committee No. 11-89, and Transfer Agent Shareholder
Accounting Advisory Committee No. 13-89, dated June 22, 1989.)
Attached is a letter the Institute has sent to the
Commissioner of Internal Revenue and the Assistant Secretary of
the Treasury for Tax Policy requesting that the B Notice mailing
scheduled for this fall be treated as a "test run" and that all B
Notices mailings, including all test runs, be sent in the spring
rather than the fall. The letter also describes the operational
burdens that will be created by the current B Notice requirements
for regulated investment companies (RICs), explains how these
burdens would be exacerbated if the B Notices were mailed in the
fall and urges reconsideration of several suggestions regarding B
Notices previously made be the Institute.
We will keep you informed of further developments.
Keith D. Lawson
Assistant General Counsel
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