December 24, 1990
TO: TAX COMMITTEE NO. 35-90
ACCOUNTING/TREASURERS COMMITTEE NO. 39-90
RE: JANUARY 7, 1990 MEETING TO DISCUSS UNIFICATION OF
DISTRIBUTION REQUIREMENTS
__________________________________________________________
As you may know, last year a Subcommittee of the Tax and
Accounting/Treasurers Committees considered methods of
alleviating some of the complexities caused by the interaction
between the distribution requirements of Subchapter M and Code
section 4982. (See Institute Memoranda to Tax Committee No. 4-90
and Accounting/Treasurers Committee No. 5-90, dated February 21,
1990; and to Tax Committee No. 2-90, dated January 12, 1990.)
One specific proposal, that ultimately was not supported by a
majority of the subcommittee, would have eliminated the dual
distribution system by placing the Subchapter M distribution
requirements generally on the excise tax years. However, because
interest in unifying the distribution requirements of Subchapter
M and section 4982 seems to have increased recently, a new
subcommittee of the Tax and Accounting/Treasurers Committees will
be formed to consider development of a unification proposal.
The first meeting of the new subcommittee will be held at
the Institute on Monday, January 7, 1991 at 1:30 p.m. Lunch will
be available before the meeting beginning at 12:00 p.m. The
regularly scheduled meeting of the full Tax Committee will take
place the next morning, Tuesday, January 8, 1991 at 10:00 a.m.
If you plan to attend the subcommittee meeting, please let
Berlaunder Barnes at the Institute (202/955-3518) know by
Thursday, January 3, 1991.
Attached to the copy of this memorandum being sent by
regular mail is a memorandum describing many of the statutory
changes that would need to be included in any legislative
proposal to unify the distribution requirements.
We will keep you informed of developments.
Keith D. Lawson
Associate General Counsel
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