December 2, 1992
TO: TAX COMMITTEE NO. 45-92
RE: INSTITUTE RECOMMENDATIONS FOR INTERNAL REVENUE SERVICE 1993
BUSINESS PLAN
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Attached is the Institute’s recommendation letter to the
Internal Revenue Service concerning the 1993 Business Plan. As
you know, the IRS Business Plan is the document in which the IRS
addresses its administrative priorities for the year. The
Institute raised two issues as priorities which should be
addressed in 1993; finalizing the proposed passive foreign
investment company ("PFIC") regulations, and issuing regulations
on the proper tax treatment of stripped coupons and stripped
bonds where the stripped interest is a variable amount. The
variable stripped coupon and bond regulations would be extremely
useful in clarifying the proper tax treatment of variable rate
synthetic municipal securities.
We will keep you informed of further developments.
David J. Mangefrida Jr.
Assistant Counsel - Tax
Attachment