[29773]
March 17, 2016
TO: TAX COMMITTEE No. 7-16 RE:LETTER TO IRS FOR YOUR REVIEW REGARDING EU RECLAIMS AND NOTICE 2016-10
Attached for your review is a draft letter from ICI to the Treasury Department and Internal Revenue Service (IRS). The letter urges modifications to Notice 2016-10 in order to enhance its value to both the industry and the IRS. Specifically, we request that:
- RICs be permitted to “carry forward” the amount of any refunded taxes that cannot be offset in the year refunded;
- netting be permitted for RICs that are held predominantly by insurance companies;
- guidance clarify that RICs may estimate, before December 31, the post-refund interest due;
- guidance clarify the manner in which qualified dividend income is calculated; and
- guidance “standardize,” to the extent possible, the terms of any required closing agreements.
Also attached are examples that illustrate the netting mechanism implemented in Notice 2016-10.
Please provide any comments on the draft letter to Ryan Lovin (ryan.lovin@ici.org or 202-326-5826) or Keith Lawson (Lawson@ici.org or 202-326-5832) by noon on Friday, March 25, 2016.
Ryan Lovin
Assistant General Counsel