March 24, 1992
TO: TAX MEMBERS NO. 16-92
ACCOUNTING/TREASURERS MEMBERS NO. 13-92
CLOSED-END FUND MEMBERS NO. 14-92
UNIT INVESTMENT TRUST MEMBERS NO. 21-92
RE: IRS PUBLISHES REVISED FORM 5452 (CORPORATE REPORT OF
NONDIVIDEND DISTRIBUTIONS)
__________________________________________________________
Attach is Revised Internal Revenue Service Form 5452
(Corporate Report of Nondividend Distributions) and the
accompanying instructions, which, as we previously informed you,
the IRS announced would be revised. (See Institute Memorandum to
Tax Members No. 3-92, Accounting/Treasurers Members No. 1-92,
Closed-End Fund Members No. 2-92 and Unit Investment Trust
Members No. 2-92, dated January 13, 1992.) The revised Form
eliminates the old Form's requirement that the Form and all
supporting documents (including various pages from the
corporation's federal income tax return) be filed by February 28.
As you may know, because of the concerns raised by the Institute
and others regarding the difficulties of filing all supporting
documents by February 28, the IRS twice delayed implementation of
the February 28 filing requirement and it never took effect.
(See, e.g., Institute Memorandum to Tax Members No. 57-90,
Accounting/Treasurers Members No. 30-90, Closed-End Fund Members
No. 51-90 and Unit Investment Trust Members No. 77-90, dated
December 20, 1990.)
The revised instructions provide that (1) a calendar year
corporation must file Form 5452 and supporting information with
the income tax return due for the tax year in which the
nondividend distributions were made and (2) a fiscal year
corporation must file Form 5452 and supporting information with
the income tax return due for the first fiscal year ending after
the calendar year in which the nondividend distributions were
made.
We will keep you informed of developments.
Keith D. Lawson
Associate Counsel - Tax
Attachment