[9401]
November 10, 1997
TO: TAX COMMITTEE No. 40-97
TASK FORCE ON INVESTMENT ADVISER/DISTRIBUTOR TAX ISSUES
RE: DECEMBER 3 MEETING ON ADVISER/DISTRIBUTOR TAX ISSUES
______________________________________________________________________________
A meeting to discuss tax issues of interest to investment advisers and distributors has
been scheduled for Wednesday, December 3 at 2:00 p.m. in the David Silver Conference Room,
which is located on the 12th Floor of the Institute’s office at 1401 H Street, N.W., Washington
DC. Lunch will be available before the meeting beginning at 1:00 p.m.
The meeting will focus primarily on issues being raised by IRS agents regarding fund
distributor treatment of 12b-1 arrangements. Specifically, agents are questioning (1) whether a
fund distributor should be required to take into income in the year fund shares are sold some
amount that may be received in future years from a 12b-1 plan and (2) whether the distributor
should be required to capitalize the commission payments to brokers and amortize them over
some period of time rather than deduct them in the year of payment. These issues were
addressed previously by IRS in TAM 9745003. The "expense" issue also was addressed in PLR
9619041.
If you plan to attend the meeting, please complete the attached response form and fax it
to my assistant Theresa Brice at 202-326-5839.
Keith D. Lawson
Associate Counsel - Tax
Attachment
ATTENDANCE RESPONSE FORM
INVESTMENT COMPANY INSTITUTE
ADVISER/DISTRIBUTOR TAX ISSUES MEETING
Wednesday, December 3, 1997
Please fax this portion by Friday, November 28, 1997 to Theresa Brice
Investment Company Institute, 202-326-5839.
YES NO
____ ____ LUNCH - 1:00 P.M.
____ ____ ADVISER/DISTRIBUTOR TAX ISSUES MEETING - 2:00 P.M.
___________________________________________
COMMITTEE MEMBER’S NAME
or __________________________________
ALTERNATE’S NAME
_________________________________________________
COMPANY NAME
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