January 12, 1990
TO: TAX COMMITTEE NO. 2-90
RE: POSSIBLE LEGISLATIVE PROPOSAL FOR UNIFIED DISTRIBUTION
REQUIREMENT
__________________________________________________________
At this week's Tax Committee meeting, we discussed whether
the Institute should propose legislation to combine the current-
law distribution requirements under Subchapter M and section 4982
into a unified distribution requirement. The prevailing, but not
unanimous, opinion at the meeting was that the simplification
resulting from only one distribution requirement probably did not
justify the complexity that would be created by moving the
Subchapter M distribution requirement to the excise tax years.
The attached memorandum prepared by outside counsel sets
forth various factors to be considered in determining whether
such a proposal should be made. Please call me at (202) 955-3585
with your comments.
We will keep you informed of developments.
Keith D. Lawson
Assistant General Counsel
Attachment
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