[35737]
June 13, 2024
TO: Tax Committee RE: FOR REVIEW: Draft 2024 ICI Spreadsheets for Year-End Tax Reporting
ICI has drafted the 2024 ICI Spreadsheets for year-end tax reporting, including the Primary Layout (used to populate IRS Form 1099-DIV), the Secondary Layout (used for state tax reporting and other relevant tax-related items), and the NRA Layout (used to populate IRS Form 1042-S), with instructions for each spreadsheet. Note the following proposed changes for 2024:
(1) Suggested target delivery dates of: (a) January 21 for the Primary Layout (b) January 28 for the Secondary Layout (c) February 4 for the NRA Layout.
(2) Pre-formatted cells: $.000000 for amounts, .000000% for percentages, mm/dd/yyyy for dates, and formulas for data populated by reference to other fields (sums).
(3) An extension indicator ("X"), used to indicate that the fund has applied for or will apply for an IRS extension to provide the information reported on the recipient copy of Form 1099-DIV. (ICI Primary, column 6. ICI Secondary, column 4).
(4) Revised instructions, intended to clarify the purpose and use of certain information.
(5) Secondary layout: Removed the column for RI 5-year gains (Column 80). The law providing for the 5-year rate expired in 2010.
(6) NRA Layout: Added optional columns that would allow reconciliation of the total distribution between (1) distributions taxable to foreign shareholders, and (2) distributions not taxable to foreign shareholders. For purposes of reconciling to the 1042-S.
Once we have general alignment from the Tax Committee, we'll engage with ICI's Transfer Agency Advisory Committee and Broker Dealer Advisory Committee to get feedback from the brokers and transfer agents that use the ICI spreadsheets. We also hope to reinforce the expectation that ICI members providing year-end shareholder tax reporting information will do so using the ICI spreadsheets, and generally do not accommodate ad-hoc requests for similar information in other custom formats.
If you have comments, suggestions, or questions, or if you're interested in joining a working group to discuss these potential changes and other recommended changes, please contact Mike Horn (michael.horn@ici.org, 202.326.5832).
Mike Horn
Deputy General Counsel - Tax