1 See Institute Memorandum to Tax Committee No. 17-97, dated May 20, 1997.
ACTION REQUESTED
June 2, 1997
VIA FAX
TO: TAX COMMITTEE No. 19-97
TASK FORCE ON ADVISER/DISTRIBUTOR TAX ISSUES
RE: IRS AUDITS--REQUEST TO SHARE IRS INFORMATION DOCUMENT
REQUESTS
______________________________________________________________________________
A member of the Tax Committee suggested that it would be helpful for members to
share copies of any information document requests ("IDRs") that they have received from the
IRS in connection with the recent IRS initiative to audit investment companies. It would also be
helpful for members to share IDRs received in connection with audits of fund advisers and
distributors, for example, IDRs relating to the following: (1) the treatment by advisers of fund
"start-up" expenses; (2) the treatment by advisers of expense waivers and reimbursements; and
(3) the treatment by distributors of Rule 12b-1 fees received from funds.
If you have IDRs that you are willing to share, please send them to the undersigned or
Keith Lawson (fax: (202) 326-5841). The Institute will then circulate copies of the IDRs collected
to members. In addition, we plan to discuss the IDRs at the special Tax Committee meeting
scheduled for June 17 (the day before the regular Committee meeting) to discuss various tax
issues affecting funds and their advisers and distributors.1 Accordingly, we would appreciate
receiving any IDRs by Thursday, June 12.
Before sending an IDR to us, please delete any information that you do not want
disclosed. It would be helpful if the IDRs were marked to indicate (1) the type of recipient (i.e.,
fund, adviser or distributor), and (2) for an IDR addressed to a fund, the general type of fund
(e.g., tax-exempt or international). If you have any questions regarding this matter, please call
the undersigned at (202) 326-5837 or Keith Lawson at (202) 326-5832.
Anne M. Barr
Associate Counsel - Tax