[16320]
July 18, 2003
TO: TAX COMMITTEE No. 40-03
RE: DRAFT SUBMISSION TO TREASURY ON DIVIDENDS FROM QUALIFIED FOREIGN
CORPORATIONS
Attached is a draft submission we plan to send to Barbara Angus, International Tax
Counsel, U.S. Treasury, on guidance the industry needs to implement effectively the 15% tax
rate on dividends from qualified foreign corporations.
We are scheduled to meet with Treasury on Wednesday, July 23rd, to discuss these
issues. Accordingly, we need any comments on the draft memo by Monday, July 21. We will
discuss the memo on the conference call scheduled for 2:00 p.m. (Eastern) that day, but I would
be happy to take any comments before then.
We intend to send the memo to Treasury after the call Monday afternoon together with
a cover letter outlining the issues we intend to raise at the meeting, including not only foreign
QDI and PFIC issues, but also country-by-country reporting of foreign tax credits and Japanese
tax treatment of U.S. RICs selling into Japan.
David Orlin
Assistant Counsel
Attachment (in .pdf format)