[16262]
July 2, 2003
TO: TAX COMMITTEE No. 37-03
MONEY MARKET FUNDS ADVISORY COMMITTEE No. 9-03
RE: SELL-SIDE DRAFT REVENUE PROCEDURE FOR TAX-EXEMPT BOND
As we previously informed you, 1 the Internal Revenue Service (the “Service”) has issued
guidance, Revenue Procedure 2002-68, that modifies and supercedes the guidance in Revenue
Procedure 2002-16 pursuant to which a regulated investment company (“RIC”) may take into
account each month its allocable share of tax-exempt income from certain synthetic variable rate
tax-exempt securities. The Institute already has filed comments, as requested by the Service,
regarding Revenue Procedure 2002-68 and potential simplified tax reporting for such tax-
exempt bond partnerships.2
We have received from David Nirenberg, an attorney representing the sell-side on these
issues, a draft Revenue Procedure (attached) that he has prepared and plans to submit to the
Service and Treasury that includes alternative reporting procedures for tax-exempt bond
partnerships. Mr. Nirenberg has asked for buy-side comments on the draft. He intends to
submit it to the Service and Treasury by Monday, July 7th. Please contact the undersigned
(202/326-5821 or cbarre@ici.org) if you have comments that you would like the Institute to
share with Mr. Nirenberg regarding the draft Revenue Procedure.
Catherine Barré
Assistant Counsel
Attachment (in .pdf format)
1 See, Institute Memoranda to Tax Committee No. 30-02 and Money Market Funds Advisory Committee No. 5-02
(15245), dated October 9, 2002.
2 See, Institute Memoranda to Tax Members No. 50-02 and Money Market Funds Advisory Committee No. 9-02
(15444), dated December 10, 2002.