Introduction›Part III. Administrative, Procedural, and Miscellaneous
SECTION 3. SCOPE
Internal Revenue Bulletin 1996-39 · 2026-10-03 edition · updated 2026-10-04 · United States
This revenue procedure applies to a corporation that meets all of the following requirements:
.01 The corporation is described in § 851(a) and § 851(b)(1).
.02 Groups of shares of the corporation have different arrangements for shareholder services or the distribution of shares or both (Qualified Groups). Expenses related to these arrangements are allocated to the Qualified Group of shares on behalf of which the expenses were incurred. The requirements in this subsection are to be interpreted in a manner consistent with the SEC’s interpretation of analogous requirements in the rules under the 1940 Act. Thus, to determine whether groups of shares have different arrangements for shareholder services or the distribution of shares, see Rule 18f–3(a)(1)(i), 17 CFR 270.18f–3(a)(1)(i), and Exemptions for Open End Management Investment Companies Issuing Multiple Classes of Shares, Investment Company Act Release No. 20,915, 60 Fed. Reg. 11,876 at 11,878 (Mar. 2, 1995).
.03 Advisory fees and other expenses related to the management of the corporation’s assets (including custodial fees and tax-return preparation fees) are allocated to all shares by net asset value, regardless of Qualified Group.
.04 Expenses other than those described in section 3.02 and 3.03 (for example, transfer agency fees) that are incurred on behalf of one or more Qualified Groups in a different amount or at a different rate from the amount or rate at which the expense is incurred on behalf of one or more other Qualified Groups are allocated either by net asset value, regardless of Qualified Group, or on the basis of the amount incurred on behalf of each Qualified Group.
.05 The rights and obligations of the shareholders of each Qualified Group are fixed in the corporation’s organizing documents. Except as otherwise provided in this revenue procedure, each Qualified Group is entitled to distributions calculated under those documents in the same manner and at the same time as all other Qualified Groups. For purposes of this calculation, expenses are allocated under those documents to each Qualified Group at the same time as to all other Qualified Groups.
.06 Each Qualified Group separately meets the requirements of § 67(c)(2)(B) (defining the required characteristics of shares of a publicly offered RIC).
Get a plain-English answer with a citation back to this text.
Ask AI about this code