April 27, 1992
TO: TAX COMMITTEE NO. 17-92
RE: REQUEST FOR LETTERS TO TREASURY REQUESTING PFIC REGULATIONS
BE MADE TEMPORARY
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As you know, the Treasury Department has recently issued
regulations which establish a mark-to-market system for regulated
investment companies ("RICs") which hold stock of passive foreign
investment companies ("PFICs"). (See Institute Memorandum to Tax
Members No. 23-91, Accounting/Treasurers Members No. 20-92,
Closed-End Fund Members No. 19-92 and International Members No.
7-92, dated April 3, 1992.) The Institute has requested that the
proposed regulations, or at least that section establishing the
mark-to-market system for RICs, be made temporary so that RICs
might be able to make use of the provisions as soon as possible.
(See Institute Memorandum to Tax Members No. 27-91,
Accounting/Treasurers Members No. 21-92, Closed-End Fund Members
No. 21-92 and International Members No. 9-92, dated April 23,
1992.)
To support our effort to have the regulation made temporary
we urge member complexes with RICs which hold PFICs to also write
to the Treasury Department requesting such action. A copy of the
Institute's letter to the Treasury is attached, and may be used
as a basis for members' letters.
We will keep you informed of further developments.
David J. Mangefrida Jr.
Assistant Counsel - Tax
Attachment