Memo #
33776

IRS and Treasury Release 2021-2022 Priority Guidance Plan - Tax Items
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[33776]

September 17, 2021

TO: ICI Members
Tax Committee SUBJECTS: Tax RE: IRS and Treasury Release 2021-2022 Priority Guidance Plan - Tax Items

 

The Treasury Department and the Internal Revenue Service ("IRS") have released the 2021-2022 Priority Guidance Plan, listing their priorities for tax regulations and other administrative guidance through June 30, 2022. The plan includes a few projects that were requested by the Institute[1] and of interest to regulated investment companies (RICs) and their shareholders, including:

  • Guidance regarding application of the cure provisions under § 851(i) for RICs
  • Guidance under § 1001 on the elimination of interbank offered rates[2]
  • Regulations under § 301.7701-3 (check-the-box elections) regarding RICs
  • Guidance under § 163(j)[3]

 

Katie Sunderland
Assistant General Counsel

 

endnotes

[1] See Institute Memorandum No. 333561, dated June 1, 2021.

[2] Proposed regulations were published on October 9, 2019; see Institute Memorandum No. 32002, dated October 10, 2019.

[3] See Institute Memorandum No. 33022, dated January 6, 2021.