November 1, 2018
Office of Associate Chief Counsel (Tax Exempt and Government Entities)
Attention: Ilya Enkishev
Internal Revenue Service (I.R.S.)
1111 Constitution Avenue, NW
Washington, DC 20224
Internal Revenue Service
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044
Via Federal eRulemaking Portal
RE: Comments on Notice 2018-68: Guidance on the Application of Section 162(m)
Dear Mr. Enkishev:
The U.S. Chamber of Commerce appreciates the opportunity to provide feedback on Notice 2018-68, guidance on the application of section 162(m), as published in the Internal Revenue Bulletin on September 4, 2018.
The attached chart identifies issues arising under Notice 2018-68 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 impacted Chamber members. These comments may be considered as representing some of the most serious issues, but are not all the issues concerning Chamber members on Notice 2018-68.
The Chamber appreciates the opportunity to provide this feedback on Notice 2018-68. The Chamber strongly urges Treasury and the I.R.S. to continue to work closely with the business community to implement the recent tax changes in a manner to ensure as little disruption as possible to normal business operations and that this law encourages 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 we work to implement our new, pro-growth tax code. Thank you for your time and attention.
Caroline L. Harris
CC: Charles P. Rettig, Commissioner, Office of the Commissioner, Internal Revenue Service,
U.S. Department of the Treasury
David J. Kautter, Assistant Secretary, Office of Tax Policy, U.S. Department of the
William M. Paul, Chief Counsel (Acting), Office of the Chief Counsel, Internal Revenue
Service, U.S. Department of the Treasury