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Revenue Procedure on Master-Feeder Funds

Pooling allowed without letter ruling

By John M. Baker, Esq.

May 10, 2001 – The Internal Revenue Service today posted a Revenue Procedure that will allow regulated investment companies to pool their assets in a master-feeder arrangement without seeking an IRS letter ruling. Rev. Proc. 2001-36.

The IRS permission will be automatic after the Revenue Procedure is published in the Internal Revenue Bulletin, scheduled for June 4, 2001. Pending letter requests may be withdrawn and the user fee refunded upon request made within 45 days after publication.

The IRS will continue to consider ruling requests from securities partnerships that are not Qualified Master-Feeder Structures.

Rev. Proc. 2001-36 is available online in PDF format at

Copyright 2001, John M. Baker, Esq., Stradley, Ronon, Stevens & Young, LLP, 1220 19th Street, N.W., Suite 700, Washington, DC 20036 – (202) 822-9611- Fax (202) 822-0140 This article was originally posted to the FundLaw List, To subscribe to FundLaw, send a blank e-mail to

Nothing herein is intended as legal or financial advice. The law is different in different jurisdictions, and the facts of a particular matter can change the application of the law. Please consult an attorney or your financial advisor before acting upon the information contained in this article.  



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