[16373]
July 30, 2003
TO: TAX MEMBERS No. 38-03
PENSION MEMBERS No. 35-03
ACCOUNTING/TREASURERS MEMBERS No. 31-03
INTERNATIONAL MEMBERS No. 26-03
UNIT INVESTMENT TRUST MEMBERS No. 25-03
TRANSFER AGENT ADVISORY COMMITTEE No. 70-03
ADVISER DISTRIBUTOR TAX ISSUES TASK FORCE No. 11-03
PENSION OPERATIONS ADVISORY COMMITTEE No. 47-03
RE: IRS AND TREASURY RELEASE 2003-2004 PRIORITY GUIDANCE PLAN
The Internal Revenue Service (“IRS”) and the Treasury Department have released their
“2003-2004 Priority Guidance Plan” (attached) listing their priorities for tax regulations and
other administrative guidance through June 30, 2004. The 2003-2004 Priority Guidance Plan
lists 268 projects. We are pleased to report that the following projects requested by the Institute1
have been included on the plan:
Items of Interest to Regulated Investment Companies (“RICs”) and RIC Shareholders
• Guidance under section 851 on the treatment of certain obligations backed by
Treasury securities for RIC diversification purposes.
• Final regulations under sections 162 and 263 regarding deduction and capitalization
of expenditures for intangible assets.
• Guidance on the definition of “qualified foreign corporation” for purposes of
taxation of dividends received by individuals.2
1 See Institute Memorandum No. 16109, to Tax Members No. 30-03, Pension Members No. 26-03,
Accounting/Treasurers Members No. 26-03, International Members No. 17-03, Transfer Agent Advisory Committee
No. 52-03 and 529 Plan Advisory Committee No. 31-03, dated May 23, 2003.
2 See Institute Memorandum No. 16341, to International Members No. 25-03 and Tax Members No. 36-03, dated July
25, 2003.
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• Guidance under section 6031 on the reporting requirements of tax-exempt bond
partnerships.
• Guidance on PFIC provisions.
Education Savings Items
• Regulations under section 529 regarding qualified tuition programs.
• Guidance on reporting requirements applicable to Coverdell education savings
accounts.
Retirement Savings Items
• Final regulations under section 408(q).
• Regulations under section 401(a)(9) on required minimum distributions.
The 2003-2004 Priority Guidance Plan also includes numerous other projects that are, or
may be, of interest to RICs and RIC shareholders and to retirement savings. These projects
include:
Items of Interest to RICs and RIC Shareholders
• Guidance regarding redemptions of corporate stock.
• Guidance regarding the active trade or business requirement of section 355(b).
• Guidance under section 382.
• Proposed regulations regarding accruals on sales of REMIC regular interests
between payment dates.
• Final regulations under section 263(g).
• Proposed regulations on notional principal contracts.
• Final regulations under section 671 regarding reporting requirements for widely-
held fixed investment trusts.
• Guidance under section 1441.
• Guidance on securities lending.
• Regulations concerning the treatment of currency gain or loss.
• Final regulations under section 704(b) regarding capital account book-up.
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• Guidance under section 704(b) regarding the allocation of foreign tax credits.
• Guidance under section 704(c).
• Guidance under section 442 regarding the period for taking into account adjustments
resulting from certain changes in annual accounting period by pass-through entities.
• Final regulations regarding electronic payee statements.
• Guidance regarding information reporting with respect to payments in lieu of
dividends made to individuals.
• Guidance necessary to facilitate electronic tax administration.
Retirement Savings Items
• Guidance on phased retirement arrangements.
• Guidance on distribution rules for rollover contributions.
• Guidance updating Rev. Rul. 81-100.
• Guidance on whether employees of a section 501(c)(3) organization who are eligible
to participate in a section 403(b) plan are excludable employees for section 401(k)
and (m) plans.
• Guidance relating to annuity plans under section 403(b).
• Guidance under section 411(d)(6).
• Guidance on use of electronic technologies for various retirement plan transactions.
• Final regulations under section 417(a).
• Guidance under section 417(e).
• Guidance under section 457.
• Revenue Procedure on model provisions for section 457(b) plans.
Keith Lawson
Senior Counsel
Attachment (in .pdf format)
Note: Not all recipients receive the attachment. To obtain a copy of the attachment, please visit our members website
(http://members.ici.org) and search for memo 16373, or call the ICI Library at (202) 326-8304 and request the
attachment for memo 16373.