June 7, 1991
TO: DANIEL MACLEAN - DREYFUS
ROBERT HARRIS - MERRILL LYNCH ASSET MGMT.
SAMUEL BEARDSLEY - T. ROWE PRICE
STEPHEN KEEN - FEDERATED INVESTORS
G. ANDREW BONNEWELL - FEDERATED INVESTORS
ROBERT GLASSMAN - DEAN WITTER INTERCAPITAL
SUSAN BENDER - CALVERT GROUP
THOMAS MAHER - FIDELITY
MONEY MARKET FUNDS AD HOC COMMITTEE NO. 14-91
RE: VARIABLE RATE TRUST CERTIFICATES
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As you know, the Institute has been working to obtain
guidance from the Treasury Department and the Internal Revenue
Service clarifying the tax treatment of certain synthetic short-
term municipal obligations generically referred to as variable
rate trust certificates. The Institute has previously met with
officials of those agencies and is proceeding with the analysis
of these instruments. Reed Shuldiner, currently a professor at
the University of Pennsylvania School of Law and a former
Treasury Department official knowledgeable in this area, has been
retained to assist in this effort.
There will be a meeting of those interested in this issue
on Wednesday, June 19, 1991 at 2:00 p.m. at which Professor
Shuldiner will discuss the outstanding issues. Soon after the
meeting, the Institute will present the Treasury and the Internal
Revenue Service with the analysis and request guidance on those
issues.
Please respond by Monday, June 17 to Berlaunder Barnes at
(202) 955-3518 it you will be attending.
David J. Mangefrida, Jr.
Assistant Counsel - Tax