1
*/ The IRS Announcement indicates that the plan has been issued in proposed,
rather than final, form because it was prepared before Clinton Administration
officials took office.
January 21, 1993
TO: TAX COMMITTEE NO. 7-93
ACCOUNTING/TREASURERS COMMITTEE NO. 5-93
RE: IRS RELEASES PROPOSED 1993 BUSINESS PLAN
__________________________________________________________
The Internal Revenue Service ("IRS") recently released a proposed
"business plan" for 1993, which identifies almost 300 regulations projects,
rulings and other administrative pronouncements that the IRS intends to issue
by the end of 1993.*/1 Among the projects that would directly affect regulated
investment companies ("RICs") and their shareholders are the following:
o proposed regulations regarding the application of section
337(d) to the conversion of a Subchapter C corporation into a
RIC, incorporating IRS Notices 88-19 and 88-96;
o final regulations on the merger of a C corporation into a
RIC;
o a revenue ruling on the value of various financial products
for RIC diversification purposes;
o a revenue ruling on the portion of earnings and profits an
open-end fund may allocate to a redeeming shareholder for
purposes of the dividends paid deduction;
o guidance on whether a RIC may deduct 12b-1 fees in computing
investment company taxable income;
o final regulations on original issue discount under section
1271;
o proposed regulations under section 1286 on various coupon
stripping issues;
o final and proposed regulations concerning selected PFIC
- 2 -
issues;
o proposed regulations under section 1441 regarding the
treatment of pensions;
o final regulations under section 3406 on backup withholding;
o a revenue procedure on the retention of digital images;
o guidance establishing a taxpayer identification number
("TIN") matching program to allow a payor to pre-check
whether a name/TIN combination provided by a payee matches a
name/TIN combination on the IRS' records.
* * *
We will keep you informed of developments.
Keith D. Lawson
Associate Counsel - Tax
Attachment