AICPA Asks to Testify at Consolidated Return Reg Hearing

The American Institute of Certified Public Accountants has asked permission to testify at the hearing on proposed regs on consolidated returns. The AICPA will comment on the treatment of foreign tax credits; the treatment of overall foreign losses; and the effective date provision.

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April 16, 1998

CC:DOM:CORP:R(REG-104062-97)

Attention: Mike Slaughter (Room 5226)

Dear Sirs and Madams:

REQUEST TO TESTIFY RE: TEMP. REG. SECTIONS 1.1502-4T AND -9T

[1] The American Institute of CPAs (AICPA) is the national professional organization of CPAS, with more than 320,000 members. The Tax Division of the Institute has a Consolidated Tax Issues Task Force (CTITF) that has comments and concerns about Temp. Reg. sections 1.1502-4T and -9T. Accordingly, we respectfully request the opportunity to testify at the public hearing on May 7, 1998.

[2] Our comments at the hearing will be directed at the following aspects of the new rules:

o treatment of foreign tax credits;

o treatment of overall foreign losses;

o effective date provision.

[3] Our comments at the hearing will be presented by Mr. William Huber, chair of our CTITF, and Mr. David Benson, chair of our International Taxation Committee.

Sincerely,

George White