Memo #
29936

ICI Draft Recommendations for 2016-2017 Treasury/IRS Priority Guidance Plan

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[29936]

May 26, 2016

TO: TAX COMMITTEE No. 12-16 RE: ICI DRAFT RECOMMENDATIONS FOR 2016-2017 TREASURY/IRS PRIORITY GUIDANCE PLAN

Notice 2016-26 invites public comment on recommendations for Treasury’s 2016-2017 Priority Guidance Plan.  [1] The Institute plans to submit a letter recommending tax items.

Attached for your review is a draft letter requesting the inclusion of several guidance projects on the 2016-2017 Priority Guidance Plan, including guidance regarding: (1) foreign tax recoveries from the EU, (2) money market fund reform, (3) FATCA, (4) RIC Mod, (5) deemed distributions under Section 305(c), (6) cost basis reporting, (7) FBAR, (8) ownership tracking requirements under Section 382, (9) electronic filing of Forms 1120-RIC, and (10) Section 529 qualified tuition programs. The letter is largely based on our past recommendations for the annual Priority Guidance Plan.  [2] The draft letter includes only tax items; the Institute will submit a separate letter with recommendations regarding retirement plan issues.

If you have comments on this draft, please contact me at ryan.lovin@ici.org by 12PM EST on Tuesday, May 31, 2016.

 

Ryan Lovin
Assistant General Counsel

Attachment

endnotes

[1] Notice 2016-26 is available at https://www.irs.gov/pub/irs-utl/n-16-26.pdf.

[2] For a copy of the Institute’s recommendations for the 2015-2016 Priority Guidance Plan, see Institute Memorandum #28960 available at: https://www.ici.org/my_ici/memorandum/memo28960.