Today the IRS released Notice 2016-10, which addresses the application of sections 853 and 905(c) to the receipt by a regulated investment company (RIC) of a tax refund that was eligible for a foreign tax credit under section 901 or 903 if that tax, when paid by the RIC, was treated as paid by the RIC’s shareholders under section 853(b)(2) because an election was made under section 853(a).  The notice describes regulations that the Treasury Department and IRS intend to issue that will allow a netting procedure which, if applied by the RICs, will greatly reduce the administrative costs and burdens on the US government, RICs, and the RIC’s shareholders.  The notice also provides guidelines for RICs wishing to obtain closing agreements relating to tax consequences arising from the receipt of such refunds.