Will reporting to the IRS Change?
No. You have always been, and continue to be, responsible for reporting cost basis to the IRS. What's changed is that we are now required to report cost basis to you and the IRS on covered shares. The reporting on noncovered shares has not changed.
Which cost-basis adjustments is a shareholder required to make?
We will only adjust the basis of shares held in an account due to activity that occurs within the same account (covered and noncovered shares are considered separate accounts). A shareholder is required to consider all potential adjustments, including across accounts, when reporting to the IRS. Some examples of potential adjustments you may need to make are listed below:
Wash sales—If you sell a fund at a loss and repurchase the same fund within 30 days before or after the sale date (61-day window), all or a portion of the loss may be disallowed due to the wash sale rules. The cost basis and holding period of the shares that were purchased, and thus triggered the wash sale, need to be adjusted. To the extent that this wash sale occurred due to covered shares sold and bought back within the same account, we will adjust and track the new basis. However, if the transaction occurred across two accounts (i.e., sale in one account and purchase in a separate account), then we cannot adjust the basis.
Load-basis deferral—If you purchase shares with a sales charge and then transfer to another fund without paying a sales charge (due to reinvestment privileges) before the 91st day after purchase, any gain or loss generated by the transfer should be adjusted by the sales charge waived. The basis of the new fund should also be adjusted by the waived sales charge.
Six-month loss—If you sell a fund at a loss after holding it for six months or less and received a long-term capital gain distribution, the short-term capital losses generated by the sale should be treated as long-term losses to the extent of long-term capital gain dividends received.
Which shares are sold first in a bifurcated account?
Noncovered shares will always be redeemed before covered shares. The cost-basis method on your account will only be used on covered shares after all noncovered shares are completely sold.
What if the shareholder doesn’t agree with the information on covered shares reported to them and the IRS on Form 1099-B?
It is ultimately the shareholder's responsibility to report the correct cost basis to the IRS. The new IRS Form 8949 provides you with an opportunity to adjust the cost basis reported on Form 1099-B. In addition to the numerical adjustment, you must also provide a reason for the adjustment based upon the standard reasons supplied by the IRS. For more information, please refer to the instructions for Schedule D.
What year-end tax reporting will a shareholder receive if he or she owns both covered and noncovered shares?
Shareholders who own covered (shares purchased after January 1, 2012) and noncovered shares (generally shares purchased prior to January 1, 2012) of a fund will be considered as owning a bifurcated (split) account. This means that for tax reporting purposes only, the shareholder’s investment in the fund will be split and grouped into covered and noncovered shares. Each group of shares will be treated as a separate account (for tax reporting purposes only), and the tax reporting will differ as described below:
Noncovered shares—We are required to report only the proceeds of a redemption to the IRS and shareholders on Form 1099-B. In addition, as a service to our shareholders, we will continue to provide them (but not the IRS) with average cost basis information in order to assist shareholders with reporting the cost basis on noncovered shares to the IRS. Shareholders are not required to use this information.
Covered shares—We are required to report the cost basis to you and the IRS on Form 1099-B. The cost basis will be computed based upon the fund’s default method of average cost, or another method of your choosing. You are required to use this information to report cost basis to the IRS.
If a shareholder owns an account that has both covered and noncovered shares, and intends to continue using the average cost-method, what will change?
As described above, there will be no change in the information we report to the IRS on noncovered shares. However, the cost basis information will now be reported on Form 1099-B instead of the average- cost-basis statement. In addition, because the fund will be considered bifurcated (contains both covered and noncovered shares), we will compute two, average-cost-basis per share amounts—one for covered shares and the other for noncovered shares.
Can a shareholder use a method other than average cost on noncovered shares?
Yes. However, we can only provide cost-basis information on noncovered shares using the average-cost method. You are not required to use the cost-basis information provided on non-covered shares and may compute your cost basis using any other IRS-approved method. Please note that if you intend to compute the cost basis manually, you should maintain detailed records of all transactions in addition to your calculation. Also, if you redeemed/exchanged out of a fund in the past using the average-cost-basis method, you may be restricted by the IRS in changing to another method.