ICI Submits Recommendations for 2023–2024 Treasury/IRS Priority Guidance Plan

[35350]

June 15, 2023

TO: Tax Committee SUBJECTS: Fund Accounting & Financial Reporting
Tax RE: ICI Submits Recommendations for 2023–2024 Treasury/IRS Priority Guidance Plan

 

Notice 2023-36 invited public comment on recommendations for Treasury's 2023–2024 Priority Guidance Plan. ICI submitted the attached letter largely based on prior recommendations except for an addition regarding Inflation Reduction Act provisions on non-regulated investment companies. The request for guidance regarding the requirement to provide written notice of tax designations has been moved to the main section of the letter given the SEC's final rule on Tailored Shareholder Reports.

The priority requests for guidance in the main section of the draft letter, include:

1. Electronic Filing and Processing of Form 8802, Application for US Residency Certification and Digitalization of Form 6166, Certification of US Tax Residency
2. Inflation Reduction Act Provisions and Non-RIC Investment Companies
3. Active Trade or Business Requirement under Section 355
4. Written Statement Regarding Tax Designations of Distributions
5. Electronic Filing and Permanent Digital Signature Relief
6. IRS Form SS-4 Daily Application Limit
7. Qualified interest income
8. Excess Foreign Tax Recoveries from European Union Member States under Santander

ICI submitted a separate letter on retirement security issues.[1]

 

Katie Sunderland
Associate General Counsel

Notes

[1] See Institute Memorandum 35346 dated June 12, 2023.