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May 26, 2017 TO: Tax Committee RE: ICI Draft Recommendations for 2017-2018 Treasury/IRS Priority Guidance Plan
Notice 2017-28 invites public comment on recommendations for Treasury’s 2017-2018 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 2017-2018 Priority Guidance Plan, including guidance regarding: (1) foreign tax recoveries from the EU, (2) FATCA, (3) RIC Mod, (4) deemed distributions under Section 305(c), (5) cost basis reporting, (6) FBAR, (7) ownership tracking requirements under Section 382, (8) electronic filing of Forms 1120-RIC, (9) Section 529 qualified tuition programs, (10) Section 851 Investments in CFCs and PFICs, and (11) Money Market Reform. 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 katie.sunderland@ici.org by 12PM EST on Thursday, June 1, 2017.
Katie Sunderland
Counsel - Tax Law
endnotes
[1] Notice 2017-28 is available at https://www.irs.gov/pub/irs-utl/notice_2017-28.pdf.
[2] For a copy of the Institute’s recommendations for the 2016-2017 Priority Guidance Plan, see Institute Memorandum No. 29936 available at https://www.ici.org/my_ici/memorandum/memo29936.