[14920]
July 12, 2002
TO: ACCOUNTING/TREASURERS COMMITTEE No. 33-02
INTERNATIONAL COMMITTEE No. 53-02
TASK FORCE ON ADVISER/DISTRIBUTOR TAX ISSUES
TAX MEMBERS No. 29-02
TRANSFER AGENT ADVISORY COMMITTEE No. 56-02
UNIT INVESTMENT TRUST COMMITTEE No. 18-02
RE: IRS AND TREASURY RELEASE 2002 PRIORITY GUIDANCE PLAN
The Internal Revenue Service (“IRS”) and the Treasury Department have released their
“2002 Priority Guidance Plan,” which lists their priorities for tax regulations and other
administrative guidance through June 30, 2003. The 2002 Priority Guidance Plan lists 250
projects. We are pleased to report that the following projects requested by the Institute1 have
been included on the plan:
• Guidance on the treatment of certain obligations backed by Treasury securities for
RIC diversification purposes.
• Guidance under sections 162 and 263 regarding deduction and capitalization of
expenditures.2
• Guidance on synthetic tax-exempt bonds.
Among the other projects that are, or may be, of interest to regulated investment
companies (“RICs”) and their shareholders, and to unit investment trusts treated as grantor
trusts and their unitholders, are the following:
• Guidance regarding redemptions of corporate stock.
• Final regulations regarding conversions of C corporations to RIC or REIT status.
1 See, e.g., Institute Memorandum to Tax Committee No. 15-02, dated May 1, 2002.
2 See, e.g., Institute Memorandum to Tax Committee No. 9-01 and Task Force on Adviser/Distributor Tax Issues,
dated February 26, 2001.
2
• Guidance regarding requests for rulings under section 355.
• Guidance regarding the active trade or business requirement of section 355(b).
• Regulations under section 529 regarding qualified tuition programs.
• Guidance on derivative contracts.
• Final regulations under section 671 regarding requirements for widely held fixed
investment trusts.
• Guidance on PFIC provisions.
• Guidance under section 1441.
• Guidance on securities lending.
• Final regulations relating to ITINs on expedited basis.
• Guidance under section 704(b) regarding capital account book-up.
• Final regulations under section 3406 to clarify the counting of notices to payors when
multiple notices are received.
• Final regulations regarding electronic payee statements.
• Guidance under section 6011 regarding the disclosure of certain large transactions.
• Guidance necessary to facilitate electronic tax administration.
Keith Lawson
Senior Counsel
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