February 18, 1992
TO: ACCOUNTING/TREASURERS COMMITTEE NO. 11-92
INDEPENDENT ACCOUTANTS ADVISORY GROUP
RE: AICPA STATEMENT OF POSITION ON RETURN OF CAPITAL
__________________________________________________________
Enclosed for your review is a copy of the AICPA's Proposed
Statement of Position (SOP): Determination, Disclosure, and
Financial Statement Presentation of Income, Capital Gain, and
Return of Capital Distributions by Investment Companies. The
proposal would require, among other things, that distributions to
shareholders in excess of GAAP-basis net income and realized
capital gains be charged (1) to undistributed net investment
income or accumulated net realized capital gains, as appropriate,
to the extent they are attributable to book/tax timing
differences, and (2) to paid-in capital to the extent they are
attributable to permanent book/tax differences.
Comments are due to the AICPA by April 10, 1992. Please
provide the Institute with any comments you wish to have included
in the Institute's response by March 31, 1992.
Donald J. Boteler
Assistant Vice President -
Operations
Enclosure