ACTION REQUESTED
July 29, 1994
TO: TAX COMMITTEE NO. 25-94
RE: DRAFT COMMENTS ON REVENUE RULING 94-40 CONCERNING RIC
PARTNERSHIP INVESTMENTS
__________________________________________________________
The Institute has prepared the attached draft comment letter
regarding IRS Revenue Ruling 94-40, which provides guidance as to
the manner in which regulated investment companies should account
for income from partnership investments for purposes of the
excise tax distribution requirements of Code section 4982. The
letter recommends that application of the ruling generally be
limited to master-feeder arrangements.
The letter responds to Announcement 94-84, which requested
comments on the appropriate scope of the application of Revenue
Ruling 94-40. Comments on the Ruling must be received by August
11, 1994.
Please contact the undersigned at (202) 326-5837 [or by fax
(202) 326-5841] with comments on the draft letter by 12:00 noon
on Thursday, August 4, 1994.
Peter J. Cinquegrani
Assistant Counsel - Tax
Attachment