On October 3, the U.S. Chamber submitted the following comments to the Treasury Department and the IRS on REG-104226-18, proposed rules relating to §965 transition tax as published in the Federal Register on August 9, 2018
click_here_to_read_the_chamber_letter_reg-104226-18.pdf
click_here_to_read_the_chamber_965_regulations_feedback.pdf
October 3, 2018
The Honorable Steven T. Mnuchin
Secretary of the Treasury
U.S Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, D.C. 20220
The Honorable Charles P. Rettig
Commissioner
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, N.W.
Washington, D.C. 20224
The Honorable David J. Kautter
Assistant Secretary (Tax Policy)
U.S. Department of the Treasury
1500 Pennsylvania Avenue, N.W.
Washington, D.C. 20220
The Honorable William M. Paul
Acting Chief Counsel and Deputy Chief
Counsel (Technical)
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, N.W.
Washington, D.C. 20224
Office of Associate Chief Counsel (International)
Attention: Leni C. Perkins
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, NW
Washington, D.C. 20224
Office of Associate Chief Counsel (International)
Attention: Karen J. Cate
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, NW
Washington, D.C. 20224
CC:PA:LPD:PR REG-104226-18
Room 5203
Internal Revenue Service
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044
Submitted via Federal eRulemaking Portal
RE: Comments on REG-104226-18 (Proposed Rules Relating to §965 Transition Tax)
Dear Sir or Madam:
The U.S. Chamber of Commerce appreciates the opportunity to provide feedback on REG-104226-18, as published in the Federal Register on August 9, 2018.
The attached chart identifies issues arising under REG-104226-18 and provides suggested solutions as well as any additional explanation the Chamber believes would be helpful in addressing the issue. This feedback is the product of extensive conversations with a very wide array of affected Chamber members. These comments may be considered as representing some of the most serious issues, but are not all the issues concerning Chamber members have regarding REG-104226-18.
The Chamber strongly urges Treasury and the I.R.S. to work closely with the business community to implement the recent tax changes in a manner that would ensure as little disruption as possible to normal business operations and encourage the U.S. economy to achieve its true growth potential. The Chamber looks forward to working with you to address these and other issues as you work to implement the new, pro-growth tax code. Thank you for your time and attention.
Sincerely,
Caroline L. Harris
CC: Lafayette “Chip” G. Harter III, Deputy Assistant Secretary (International Tax Affairs),
U.S. Department of the Treasury
Douglas L. Poms, International Tax Counsel, U.S. Department of the Treasury
Brian Jenn, Deputy International Tax Counsel, U.S. Department of the Treasury
Brenda L. Zent, Special Advisor on International Taxation, U.S. Department of the Treasury
Marjorie A. Rollinson, Associate Chief Counsel (International), Internal Revenue Service
Daniel M. McCall, Deputy Associate Chief Counsel (International), Internal Revenue Service
Raymond J. Stahl, Senior Counsel, Office of Associate Chief Counsel (International), Internal Revenue Service
John J. Merrick, Special Counsel, Office of Associate Chief Counsel (International), Internal Revenue Service
