1 See Institute Memorandum to Tax Committee No. 3-98, dated January 16, 1998.
2 See Institute Memorandum to Accounting/Treasurers Members No. 48-97 and Tax Members No. 45-97, dated
November 12, 1997.
[9627]
VIA FAX
January 30, 1998
TO: TAX COMMITTEE No. 4-98
PERSONS ATTENDING FEBRUARY 3 MEETING
RE: PRELIMINARY AGENDA -- TAX COMMITTEE MEETING
______________________________________________________________________________
February 3 Meeting to Discuss Institute Comments to be Submitted on Notice 97-64
As you know, 1 a meeting to discuss IRS Notice 97-64 -- which provides guidance regarding
regulations that IRS will issue to implement the 1997 capital gains legislative changes2 -- will be held on
Tuesday, February 3 at 2:00 p.m. in the 11th Floor Conference Room of the Institute’s offices at 1401 H
Street N.W., Washington DC. Lunch will be available before the meeting, beginning at 1:00 p.m.
In preparation for the meeting, we have prepared the attached working outline of comments to
be submitted by the Institute. The outline addresses the following topics:
(1) issues relating to bifurcation under the notice;
(2) additional improvements to the rules for coordinating the income tax and excise tax
regimes (i.e., full bifurcation and/or the glitch fixes);
(3) application of the six-month rule of section 852(b)(4)(A) under section 1(h);
(4) the treatment of capital loss carryovers under section 1(h); and
(5) the interaction of the constructive sale rules of section 1259 and the excise tax rules of
section 4982.
February 3 Dinner for Cathy Heron
The February 3 dinner for Cathy Heron will be held at the Occidental Grill, in the Willard
Complex at Pennsylvania Avenue and 14th Street, N.W., Washington, D.C. Cocktails will begin at 6:00
p.m. in the Truman Bar, with dinner served at 6:45 p.m.
February 4 Tax Committee Meeting and Preliminary Agenda
- 2 -
The Tax Committee meeting will be held on Wednesday, February 4, at 10:00 a.m., in the David
Silver Conference Room on the 12th floor of the Institute’s offices. A luncheon will follow the meeting.
The preliminary meeting agenda for the meeting is attached. Please review the agenda and bring
with you to the meeting any memoranda about which you have specific questions or comments.
Keith D. Lawson
Associate Counsel
Attachments