MEETING ON TAX AND ACCOUNTING ALLOCATION ISSUES RELATED TO MASTER FUND/FEEDER FUND STRUCTURES

December 18, 1992 TO: TAX COMMITTEE NO. 47-92 ACCOUNTING/TREASURERS COMMITTEE NO. 47-92 RE: MEETING ON TAX AND ACCOUNTING ALLOCATION ISSUES RELATED TO MASTER FUND/FEEDER FUND STRUCTURES __________________________________________________________ The Institute has scheduled a meeting at 10:00 a.m. on Friday, January 22, 1993, to discuss the tax and accounting issues concerning allocations of income which arise in a master fund/feeder fund structure. The discussion will cover issues such as the proper allocation period, the treatment of unrecognized gains and losses and the interaction between the allocation rules and the requirements of Subchapter M of the Internal Revenue Code. We also would welcome any suggestions you might have for other items for the agenda. Please contact the undersigned at (202) 955-3521 or by fax at (202) 659-1519 with your suggestions. It is anticipated that the meeting will last until 2:30 or 3:00 p.m. Lunch will be served during the meeting. If you are planning to attend the meeting, please either call Cynthia Lutes, at (202) 955-3587, or return the attached response form to her (by fax or mail), no later than Monday, January 19, 1992. David J. Mangefrida Jr. Assistant Counsel - Tax